March 22, 2021 • 20 mins
The U.S. Environmental Protection Agency's first major revisions to the original 1991 Lead and Copper Rule present broad implications for homeowners, schools and local water utilities. Intended to improve children’s health by further reducing lead exposure from corroding pipes, the revised regulation places greater responsibilities on municipalities to act – but also applies to pipes within homes and schools. On this episode of Speaking of Design, HDR Drinking Water Director Chance Lauderdale discusses the challenges presented by the LCR revisions and how a more holistic approach can help utilities prepare for the future.
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(00:03):
I'm John Torek. And I'm Danny Sullivan. And
you're listening to Speaking of Design, bringing you
the stories of the engineers and architects
who are transforming
the world one project at a time. Today,
Waterdale, One of the drinking water industry's leading
experts on biofiltration.
We'll talk with Chance about the EPA's new
(00:23):
revisions to the lead and copper rule and
what that means to everyone from homeowners to
schools to local water utilities.
My great grandmother, Ruby McNair, was
the first female mayor of a little town
called Archer, Florida from 1960 to 1964.
(00:45):
It was the only time she'd ever run
for office, and she was 60 years old
when she did. That's Chance Lauderdale,
drinking water director at HDR. As soon as
she won that week, she actually got on
a train and went to DC to begin
lobbying the Florida senators
for some funds with the explicit intent to
build a water system for the community. And,
(01:06):
she got a million dollar grant and used
that to develop some wells and build a
water tower. And that was completed, I think,
in, like, 1963.
It still still stands there today. As a
child growing up in the Florida Panhandle,
Chance already felt a calling to a career
that would follow in his great grandmother's footsteps.
Honestly, as like a eight year old kid,
I would have to walk up and down
the beach and pick up all the trash
(01:27):
that, like, washed ashore and, you know,
being annoyed at that, it kinda sunk in
as well. You know, honestly, like most of
my generation, I'd probably lived and breathed doctor
Seuss. That said, The Lorax was one that
stood above a lot of the books that
I really love. It's like a kid sized
serving of good stewardship and resource management,
and it, also is a really explicit call
to action for environmentalism
(01:48):
and conservation. I remember that there was a
poignant line at the end of it, and
it's unless someone like you cares a whole
awful lot,
nothing is going to get better. It's not.
Chance took those words to heart, pursuing a
bachelor's degree, master's, and doctorate,
all in environmental engineering,
from the University of Florida. My dissertation
was really trying to open a black box
(02:09):
of an emerging treatment technology
in the drinking water market, and that's biological
filtration. And, certainly, this is a treatment technology
that existed before my PhD,
but my PhD was
one of several
parallel research efforts that were going on in
the industry at the time that really sought
to open that up and develop guidance
that's helped inform
(02:30):
utilities across the country and in some parts
of Europe and and other parts of the
world. Chance further explained the difference between traditional
drinking water treatment and biofiltration.
When we traditionally look at filtration and a
water treatment process, it is what it sounds
like. There are suspended particles, colloids,
pathogens
that are present in our water that go
(02:51):
through a filtration process where they're separated out
through various physical chemical processes. For example, a
chemical such as chlorine is often added to
the water to remove viruses, bacteria, and other
pathogens that might cause illness. While biofiltration
sounds more like a solution which had its
seeds planted in the mind of a child
reading The Lorax.
(03:12):
You're leveraging mother nature. Right? So there's inherent
efficiencies.
These contaminants are present in environmental bodies. They're
present in our source waters and in our
soils.
And mother nature has already figured out a
way through
environmental cycling, through microbial cycling to manage a
lot of these contaminants to keep them from
accumulating. In other words, using bacteria
(03:33):
strategically
to naturally consume contaminants in the water. What
the biological front does on that is it
actually leverages biology
and biological metabolism
to also take out dissolved compounds
that are present in the water. You know,
instead of just particles, we can also remove
contaminants
like pharmaceuticals,
(03:54):
disinfection byproducts, or their precursors,
and the biological process is sustainable in that
you're not continually adding chemicals or tons of
energy into the process. And then it also
doesn't really produce a concentrated
waste stream. Chance estimated that well over 30,000,000,000
gallons of water are now being treated using
some form of biofiltration.
Over 1,000,000,000 of which are using strategies stemming
(04:15):
from his research.
But today, we're focusing on an issue that's
garnered more headlines since the water crisis hit
Flint, Michigan, preventing lead and copper from getting
into drinking water through the pipes that carry
it to homes, schools, and businesses.
Joe, believe it or not, over the past
century, we've had a growing awareness on the
(04:36):
negative health impacts associated with lead exposure, particularly
in children. And we actually started to see
some regulatory action in the seventies and early
eighties
when we started to limit, you know, lead
in gasoline and lead in paint.
Those actions resulted in a significant drop in
lead exposure for children, which has been associated
(04:57):
with irreversible
behavioral and developmental
challenges,
anemia,
memory loss, weakness,
pregnancy and fertility issues,
and cancer.
Yet there remained another significant source of lead
to consider in our plumbing. Lead is a
material that was heavily used
for plumbing and conveyance infrastructure
(05:18):
through the industrial revolution and up until
World War two. We saw really heavy
reliance on lead as a reliable pipe material
because
it's malleable.
You can easily bend it around corners. It
resists corrosion
for the most part, and it was really
one of the better available technologies
(05:38):
at the time. After World War two, the
use of lead began to diminish, but we
still saw
some contractors and some builders
included up through the nineteen seventies. In fact,
it's estimated that there are still six to
9,000,000 service lines containing lead in The US,
carrying water to tens of millions of people.
(06:00):
It was then recognized that a lot of
the lead that people were getting exposed through
through water systems was actually coming from their
plumbing and from some of the piping that
actually led to their house. And so in
1986,
the EPA mandated, quote, unquote, lead free plumbing
that dropped the acceptable levels of lead to
be at 8% in wetted surfaces. That was
(06:21):
that's credited with a pretty big drop in
exposure. In 1991,
the US EPA took that one step further
when it published a new regulation
known as the Lead and Copper Rule. The
intent there was to really
increase the monitoring and increase
the characterization
of lead coming from what's called a service
(06:43):
line, and that's the line from the water
main down the street and the home itself.
The rule requires drinking water utilities to sample
drinking water at customers' taps.
If the lead or copper concentration reaches what
the EPA calls an action limit, then the
drinking water
utility must inform the public and take further
actions to protect their health
(07:03):
ranging from corrosion control measures
to complete service line replacement.
That lead has formed stable layers of scale
on the pipe after years of operation.
And usually, when there are changes
in water chemistry, so changes in finished water
stability,
those scales can become unstable, and they can
(07:24):
release lead to the customer. And so that's
why you've got instances
like Flint, Michigan, where the utility went to
a different water source and treatment facility, and
that caused lead release and exposure to the
community.
And then even
areas like DC Water
where there were some treatment changes at the
(07:45):
treatment plant that was believed to be responsible
for lead release
about twenty years ago. Though the lead and
copper rule has undergone minor revisions over the
last thirty years. The original 1991
rule yielded positive results.
We saw a drastic increase in lead exposure
to many of the communities.
(08:05):
This is found in parallel
to a continued drop in the lead blood
levels of children across The US, a pretty
precipitous drop that is continuing today.
The rule also improves transparency
and communication to the public in terms of
what was coming out of their tap. And
(08:25):
the rule also you know, it elevated the
awareness of this overall risk to our community.
However, three decades of implementation
and data
have also suggested room for improvement. The original
1991 rule, it did not have a lot
of teeth on the replacement side. In other
words, a utility would have several opportunities
to continue to optimize their system,
(08:46):
continue to optimize
their water quality. I think the biggest limitations
of the rule
are it provided
too many opportunities
to avoid service line replacement, and so we
really still have a lot of that buried
lead infrastructure
across The US. Which brings us to present
day. In December 2020, the EPA released its
(09:06):
first major revisions to the rule, which are
still in the process of being finalized.
The revisions include six main components. -The first
component is for utilities to better identify and
inventory
their lead service lines. -Second,
strengthening drinking water treatment requirements.
-And third,
driving more lead service line replacements. -Including
(09:28):
state of the science in terms of corrosion
inhibition and corrosion control,
as well as adding a new
limit called a trigger level to
lead regulation, and that's 10 parts per billion.
And at the trigger level, utilities that hit
that level
are now required to develop a lead service
line replacement plan
(09:50):
so that when they exceed
the action level, which hasn't changed 15 parts
per billion,
they actually have a mandatory
lead service line replacement program they have to
follow.
And that is
over a two year period, four consecutive six
month intervals,
they have to replace 3%
of their total lead service line inventory.
(10:13):
And this is,
substantial
expansion of the existing rule because now utilities
are no longer able to test out of
having to do lead service line replacement. The
fourth component,
better guidance on sampling procedures.
And fifth, better public communication of risks. There
is additional language in the rule
to improve
(10:34):
public communication,
and that includes
twenty four hour notifications to homeowners
where an action level, it seems, has been
notified, publishing
the lead service line inventory so that it's
accessible to everyone in the community so they
understand where it is and where replacement programs
might be occurring.
In addition, the new rule requires
(10:55):
additional public outreach and communication
with primacy agencies
and health agencies
to help with epidemiological data in case there
has been any exposure within the community. And
finally, the sixth component,
an emphasis on testing in schools and childcare
facilities. And what this is gonna require is
that every single utility
(11:15):
will monitor for lead at fountains and taps
at every school and registered day care facility
within their system
once every five years. So 20% of all
schools and day care facilities
have to be sampled for lead, and then
the utility will have to communicate those results
and recommend and potentially recommendations
(11:36):
to the school board and associated
school leaders.
A significant change in regulation brings significant challenges
for local water providers across the country. The
two biggest challenges are the communication piece because
the new rule is gonna require substantially more
(11:57):
transparency,
both when lead is identified
at the tap as well as when lead
service lines are identified through the inventory development.
And so, you know, utilities are going to
need to be able to communicate that they're
improving conditions of the community, that they are
being transparent,
that they are
(12:18):
protecting their brand
as protectors of public health. The impact on
schools and childcare facilities also introduces a new
element. The communication with the school districts and
the day cares is gonna be an elegant
balance because utilities don't own the premise plumbing
on those schools. They don't own the water
fountains. They don't own the solder within the
(12:39):
plumbing, but they're providing water that has water
quality that could cause lead corrosion from that
premise plumbing. Which really gets to the heart
of what makes the lead and copper rule
so complicated
beyond the science.
If the federal government institutes a regulation on
a service provided by local municipalities
and following that regulation requires infrastructure replacement
(13:01):
that those utilities don't own, then how will
the replacement of those lead service lines be
funded? I think that the next major element
that's gonna be important for utilities to address
is the financing.
This is going to be
a modest rule for utilities that are relatively
new, that have newer infrastructure where most of
the community was developed
(13:24):
post 1960.
But those utilities that have older systems where
they saw a lot of growth in the
forties and thirties, this could be a very
expensive proposition. A proposition that almost certainly won't
be shouldered alone by the utilities.
As they look to be proactive for lead
service and replacement,
you're talking huge, huge expenses in the millions
(13:44):
or even modest sized communities. The homeowner is
also going to have cost burden. The cost
to replace a lead service line pipe for
the homeowner on their side
is likely going to average somewhere between 8
and $10,000.
So how this is funded, how it's financed,
how we push forward this rule that really
(14:05):
is seeking to serve
the underrepresented
and underserved
elements of our community,
yet still have to figure out a way
to carry both the cost on the utility
side and the cost on the private owner
side is going to be a challenge. However,
there are options for utilities.
There is EPA guidance to show and highlight
(14:25):
what these options are and some of the
many nuances. There is federal funding like WIPA.
There's also state revolving funds where utilities can
get low interest loans. There's also the ability
to add a surcharge to a utility bill
to cover the capital cost of doing the
lead service line replacement.
There's also non ad valorem taxes that can
be assessed on properties to help support the
(14:47):
payment. The infrastructure replacement required by regulations like
the lead and copper rule also has utilities
stepping back to look at all the services
they provide
more holistically.
The one water paradigm
is something that utilities across The US and
even the world have been moving towards over
the past several years, if not decade. Really,
(15:07):
what this approach is is to develop water
planning that looks at water usage and treatment
and management with a view of the complete
water cycle, so the entire
hydrologic cycle, and how people and aquatic ecosystems
can be impacted either upstream or downstream. It's
also an intent that there's a single voice
and message that provides a a holistic overview
(15:30):
of how all these pieces fit together. Which
includes a wide range of water related services
that the general public takes for granted as
long as they're operating as expected. So think
about you've got your drinking water that feeds
into your community. Your community then has wastewater
that goes into a collection system, into the
water reclamation facility or wastewater treatment facility. That's
(15:51):
either then discharged into a receiving body or
it's injected into the groundwater
or it's recycled through a reclaimed water system,
purple pipe, or we even have potable reuse.
And those are just really high level overview
of the interconnection of those elements, but you
also have stormwater and you also have rainwater
(16:12):
capture and other things that kinda fit into
the one water paradigm. Whereas in the past,
many communities might have had separate departments and
separate budgets for a drinking water and wastewater
treatment, for example. The one water paradigm in
this holistic management
considers
how investments work within in the individual sector
and how that investment can impact other sectors
(16:33):
positively or negatively, providing opportunities or challenges. The
lead and copper rule is a major investment.
It will require many communities, cities, utilities
to reprioritize
how they're looking at everything across the board,
including their wastewater systems or their stormwater systems.
So a one water approach could help utilities
(16:56):
do that prioritization,
see whether addressing lead and copper rule fits
into that bigger picture. One specific challenge that
can benefit from that approach arises
when a chemical added to drinking water to
prevent corrosion of pipes
needs to be removed from wastewater before it's
discharged into streams and groundwater.
The best available corrosion control treatment technology
(17:17):
that's being recommended
within the lead and copper rule revisions is
orthophosphate
phosphorus addition. And so orthophosphate
is a
corrosion inhibitor. It forms
stable metal complexes with lead so that it
no longer comes out of solution under a
wide range of water quality. The problem is
is that the concentrations of orthophosphate,
(17:38):
phosphorus that are going to be added
will have downstream impacts to many wastewater treatment
systems
and effluent discharge. And so utilities that, you
know, are operating their wastewater treatment system to
remove phosphorus, they're now gonna need to reevaluate
their treatment process in some instances
because there's gonna be additional phosphorus coming in.
(18:00):
And so there's likely going to be some
collaboration
between
drinking water and wastewater sides of utilities
to get a better understanding of this, to
optimize it further, and to prepare for potential
changes on effluent management. Implementing changes related to
the lead and copper rule won't be simple
for water utilities,
(18:20):
though Chance said he expects preliminary measures to
begin soon. It's still gonna take a little
time for many of the state primacy agencies
to adapt and implement the rule locally. And
so a year from now, you'll probably still
have many utilities across The US waiting on
their state primacy agencies to roll out the
(18:40):
rule within their state. That said, I fully
anticipate utilities
everywhere
to begin
working on some of the major elements of
the rule, including the lead service line inventory
and then
getting their field staff accustomed to and trained
on the new recommendations on sampling and monitoring.
That said, the lead and copper rule has
(19:02):
experts like Chance digging into the details to
be prepared to provide guidance. I think the
the biggest thing that people in our industry
can do to help our utility clients and
to help these water systems
address the new rule is at the planning
level right now. And so the rule is
huge. It's nearly 300 pages. And as I
(19:23):
said, there are six major elements, and each
of those elements inherently have a wide range
of requirements and things that utilities are gonna
need to understand. And so I think that
it's upon the consulting industry to help educate
utilities,
help understand the requirements of the rule, help
benchmark their current practices,
and then identify the steps steps that are
(19:44):
gonna need to be taken in a systematic
and intentional way
to reach compliance
for the new rule when it's required.
For more information on this podcast, visit hdrinc.com/speakingofdesign.
You'll find links to pictures, articles, and more
information about this project.
If you like what you heard, be sure
(20:06):
to rate us or leave feedback on iTunes,
Stitcher, or wherever you get your podcasts.
I'm John Torek. And I'm Danny Sullivan. And
you're listening to Speaking of Design, bringing you
the stories of the engineers and architects
who are transforming
the world one project at a time. Today,
Waterdale, One of the drinking water industry's leading
experts on biofiltration.
We'll talk with Chance about the EPA's new
(00:23):
revisions to the lead and copper rule and
what that means to everyone from homeowners to
schools to local water utilities.
My great grandmother, Ruby McNair, was
the first female mayor of a little town
called Archer, Florida from 1960 to 1964.
(00:45):
It was the only time she'd ever run
for office, and she was 60 years old
when she did. That's Chance Lauderdale,
drinking water director at HDR. As soon as
she won that week, she actually got on
a train and went to DC to begin
lobbying the Florida senators
for some funds with the explicit intent to
build a water system for the community. And,
(01:06):
she got a million dollar grant and used
that to develop some wells and build a
water tower. And that was completed, I think,
in, like, 1963.
It still still stands there today. As a
child growing up in the Florida Panhandle,
Chance already felt a calling to a career
that would follow in his great grandmother's footsteps.
Honestly, as like a eight year old kid,
I would have to walk up and down
the beach and pick up all the trash
(01:27):
that, like, washed ashore and, you know,
being annoyed at that, it kinda sunk in
as well. You know, honestly, like most of
my generation, I'd probably lived and breathed doctor
Seuss. That said, The Lorax was one that
stood above a lot of the books that
I really love. It's like a kid sized
serving of good stewardship and resource management,
and it, also is a really explicit call
to action for environmentalism
(01:48):
and conservation. I remember that there was a
poignant line at the end of it, and
it's unless someone like you cares a whole
awful lot,
nothing is going to get better. It's not.
Chance took those words to heart, pursuing a
bachelor's degree, master's, and doctorate,
all in environmental engineering,
from the University of Florida. My dissertation
was really trying to open a black box
(02:09):
of an emerging treatment technology
in the drinking water market, and that's biological
filtration. And, certainly, this is a treatment technology
that existed before my PhD,
but my PhD was
one of several
parallel research efforts that were going on in
the industry at the time that really sought
to open that up and develop guidance
that's helped inform
(02:30):
utilities across the country and in some parts
of Europe and and other parts of the
world. Chance further explained the difference between traditional
drinking water treatment and biofiltration.
When we traditionally look at filtration and a
water treatment process, it is what it sounds
like. There are suspended particles, colloids,
pathogens
that are present in our water that go
(02:51):
through a filtration process where they're separated out
through various physical chemical processes. For example, a
chemical such as chlorine is often added to
the water to remove viruses, bacteria, and other
pathogens that might cause illness. While biofiltration
sounds more like a solution which had its
seeds planted in the mind of a child
reading The Lorax.
(03:12):
You're leveraging mother nature. Right? So there's inherent
efficiencies.
These contaminants are present in environmental bodies. They're
present in our source waters and in our
soils.
And mother nature has already figured out a
way through
environmental cycling, through microbial cycling to manage a
lot of these contaminants to keep them from
accumulating. In other words, using bacteria
(03:33):
strategically
to naturally consume contaminants in the water. What
the biological front does on that is it
actually leverages biology
and biological metabolism
to also take out dissolved compounds
that are present in the water. You know,
instead of just particles, we can also remove
contaminants
like pharmaceuticals,
(03:54):
disinfection byproducts, or their precursors,
and the biological process is sustainable in that
you're not continually adding chemicals or tons of
energy into the process. And then it also
doesn't really produce a concentrated
waste stream. Chance estimated that well over 30,000,000,000
gallons of water are now being treated using
some form of biofiltration.
Over 1,000,000,000 of which are using strategies stemming
(04:15):
from his research.
But today, we're focusing on an issue that's
garnered more headlines since the water crisis hit
Flint, Michigan, preventing lead and copper from getting
into drinking water through the pipes that carry
it to homes, schools, and businesses.
Joe, believe it or not, over the past
century, we've had a growing awareness on the
(04:36):
negative health impacts associated with lead exposure, particularly
in children. And we actually started to see
some regulatory action in the seventies and early
eighties
when we started to limit, you know, lead
in gasoline and lead in paint.
Those actions resulted in a significant drop in
lead exposure for children, which has been associated
(04:57):
with irreversible
behavioral and developmental
challenges,
anemia,
memory loss, weakness,
pregnancy and fertility issues,
and cancer.
Yet there remained another significant source of lead
to consider in our plumbing. Lead is a
material that was heavily used
for plumbing and conveyance infrastructure
(05:18):
through the industrial revolution and up until
World War two. We saw really heavy
reliance on lead as a reliable pipe material
because
it's malleable.
You can easily bend it around corners. It
resists corrosion
for the most part, and it was really
one of the better available technologies
(05:38):
at the time. After World War two, the
use of lead began to diminish, but we
still saw
some contractors and some builders
included up through the nineteen seventies. In fact,
it's estimated that there are still six to
9,000,000 service lines containing lead in The US,
carrying water to tens of millions of people.
(06:00):
It was then recognized that a lot of
the lead that people were getting exposed through
through water systems was actually coming from their
plumbing and from some of the piping that
actually led to their house. And so in
1986,
the EPA mandated, quote, unquote, lead free plumbing
that dropped the acceptable levels of lead to
be at 8% in wetted surfaces. That was
(06:21):
that's credited with a pretty big drop in
exposure. In 1991,
the US EPA took that one step further
when it published a new regulation
known as the Lead and Copper Rule. The
intent there was to really
increase the monitoring and increase
the characterization
of lead coming from what's called a service
(06:43):
line, and that's the line from the water
main down the street and the home itself.
The rule requires drinking water utilities to sample
drinking water at customers' taps.
If the lead or copper concentration reaches what
the EPA calls an action limit, then the
drinking water
utility must inform the public and take further
actions to protect their health
(07:03):
ranging from corrosion control measures
to complete service line replacement.
That lead has formed stable layers of scale
on the pipe after years of operation.
And usually, when there are changes
in water chemistry, so changes in finished water
stability,
those scales can become unstable, and they can
(07:24):
release lead to the customer. And so that's
why you've got instances
like Flint, Michigan, where the utility went to
a different water source and treatment facility, and
that caused lead release and exposure to the
community.
And then even
areas like DC Water
where there were some treatment changes at the
(07:45):
treatment plant that was believed to be responsible
for lead release
about twenty years ago. Though the lead and
copper rule has undergone minor revisions over the
last thirty years. The original 1991
rule yielded positive results.
We saw a drastic increase in lead exposure
to many of the communities.
(08:05):
This is found in parallel
to a continued drop in the lead blood
levels of children across The US, a pretty
precipitous drop that is continuing today.
The rule also improves transparency
and communication to the public in terms of
what was coming out of their tap. And
(08:25):
the rule also you know, it elevated the
awareness of this overall risk to our community.
However, three decades of implementation
and data
have also suggested room for improvement. The original
1991 rule, it did not have a lot
of teeth on the replacement side. In other
words, a utility would have several opportunities
to continue to optimize their system,
(08:46):
continue to optimize
their water quality. I think the biggest limitations
of the rule
are it provided
too many opportunities
to avoid service line replacement, and so we
really still have a lot of that buried
lead infrastructure
across The US. Which brings us to present
day. In December 2020, the EPA released its
(09:06):
first major revisions to the rule, which are
still in the process of being finalized.
The revisions include six main components. -The first
component is for utilities to better identify and
inventory
their lead service lines. -Second,
strengthening drinking water treatment requirements.
-And third,
driving more lead service line replacements. -Including
(09:28):
state of the science in terms of corrosion
inhibition and corrosion control,
as well as adding a new
limit called a trigger level to
lead regulation, and that's 10 parts per billion.
And at the trigger level, utilities that hit
that level
are now required to develop a lead service
line replacement plan
(09:50):
so that when they exceed
the action level, which hasn't changed 15 parts
per billion,
they actually have a mandatory
lead service line replacement program they have to
follow.
And that is
over a two year period, four consecutive six
month intervals,
they have to replace 3%
of their total lead service line inventory.
(10:13):
And this is,
substantial
expansion of the existing rule because now utilities
are no longer able to test out of
having to do lead service line replacement. The
fourth component,
better guidance on sampling procedures.
And fifth, better public communication of risks. There
is additional language in the rule
to improve
(10:34):
public communication,
and that includes
twenty four hour notifications to homeowners
where an action level, it seems, has been
notified, publishing
the lead service line inventory so that it's
accessible to everyone in the community so they
understand where it is and where replacement programs
might be occurring.
In addition, the new rule requires
(10:55):
additional public outreach and communication
with primacy agencies
and health agencies
to help with epidemiological data in case there
has been any exposure within the community. And
finally, the sixth component,
an emphasis on testing in schools and childcare
facilities. And what this is gonna require is
that every single utility
(11:15):
will monitor for lead at fountains and taps
at every school and registered day care facility
within their system
once every five years. So 20% of all
schools and day care facilities
have to be sampled for lead, and then
the utility will have to communicate those results
and recommend and potentially recommendations
(11:36):
to the school board and associated
school leaders.
A significant change in regulation brings significant challenges
for local water providers across the country. The
two biggest challenges are the communication piece because
the new rule is gonna require substantially more
(11:57):
transparency,
both when lead is identified
at the tap as well as when lead
service lines are identified through the inventory development.
And so, you know, utilities are going to
need to be able to communicate that they're
improving conditions of the community, that they are
being transparent,
that they are
(12:18):
protecting their brand
as protectors of public health. The impact on
schools and childcare facilities also introduces a new
element. The communication with the school districts and
the day cares is gonna be an elegant
balance because utilities don't own the premise plumbing
on those schools. They don't own the water
fountains. They don't own the solder within the
(12:39):
plumbing, but they're providing water that has water
quality that could cause lead corrosion from that
premise plumbing. Which really gets to the heart
of what makes the lead and copper rule
so complicated
beyond the science.
If the federal government institutes a regulation on
a service provided by local municipalities
and following that regulation requires infrastructure replacement
(13:01):
that those utilities don't own, then how will
the replacement of those lead service lines be
funded? I think that the next major element
that's gonna be important for utilities to address
is the financing.
This is going to be
a modest rule for utilities that are relatively
new, that have newer infrastructure where most of
the community was developed
(13:24):
post 1960.
But those utilities that have older systems where
they saw a lot of growth in the
forties and thirties, this could be a very
expensive proposition. A proposition that almost certainly won't
be shouldered alone by the utilities.
As they look to be proactive for lead
service and replacement,
you're talking huge, huge expenses in the millions
(13:44):
or even modest sized communities. The homeowner is
also going to have cost burden. The cost
to replace a lead service line pipe for
the homeowner on their side
is likely going to average somewhere between 8
and $10,000.
So how this is funded, how it's financed,
how we push forward this rule that really
(14:05):
is seeking to serve
the underrepresented
and underserved
elements of our community,
yet still have to figure out a way
to carry both the cost on the utility
side and the cost on the private owner
side is going to be a challenge. However,
there are options for utilities.
There is EPA guidance to show and highlight
(14:25):
what these options are and some of the
many nuances. There is federal funding like WIPA.
There's also state revolving funds where utilities can
get low interest loans. There's also the ability
to add a surcharge to a utility bill
to cover the capital cost of doing the
lead service line replacement.
There's also non ad valorem taxes that can
be assessed on properties to help support the
(14:47):
payment. The infrastructure replacement required by regulations like
the lead and copper rule also has utilities
stepping back to look at all the services
they provide
more holistically.
The one water paradigm
is something that utilities across The US and
even the world have been moving towards over
the past several years, if not decade. Really,
(15:07):
what this approach is is to develop water
planning that looks at water usage and treatment
and management with a view of the complete
water cycle, so the entire
hydrologic cycle, and how people and aquatic ecosystems
can be impacted either upstream or downstream. It's
also an intent that there's a single voice
and message that provides a a holistic overview
(15:30):
of how all these pieces fit together. Which
includes a wide range of water related services
that the general public takes for granted as
long as they're operating as expected. So think
about you've got your drinking water that feeds
into your community. Your community then has wastewater
that goes into a collection system, into the
water reclamation facility or wastewater treatment facility. That's
(15:51):
either then discharged into a receiving body or
it's injected into the groundwater
or it's recycled through a reclaimed water system,
purple pipe, or we even have potable reuse.
And those are just really high level overview
of the interconnection of those elements, but you
also have stormwater and you also have rainwater
(16:12):
capture and other things that kinda fit into
the one water paradigm. Whereas in the past,
many communities might have had separate departments and
separate budgets for a drinking water and wastewater
treatment, for example. The one water paradigm in
this holistic management
considers
how investments work within in the individual sector
and how that investment can impact other sectors
(16:33):
positively or negatively, providing opportunities or challenges. The
lead and copper rule is a major investment.
It will require many communities, cities, utilities
to reprioritize
how they're looking at everything across the board,
including their wastewater systems or their stormwater systems.
So a one water approach could help utilities
(16:56):
do that prioritization,
see whether addressing lead and copper rule fits
into that bigger picture. One specific challenge that
can benefit from that approach arises
when a chemical added to drinking water to
prevent corrosion of pipes
needs to be removed from wastewater before it's
discharged into streams and groundwater.
The best available corrosion control treatment technology
(17:17):
that's being recommended
within the lead and copper rule revisions is
orthophosphate
phosphorus addition. And so orthophosphate
is a
corrosion inhibitor. It forms
stable metal complexes with lead so that it
no longer comes out of solution under a
wide range of water quality. The problem is
is that the concentrations of orthophosphate,
(17:38):
phosphorus that are going to be added
will have downstream impacts to many wastewater treatment
systems
and effluent discharge. And so utilities that, you
know, are operating their wastewater treatment system to
remove phosphorus, they're now gonna need to reevaluate
their treatment process in some instances
because there's gonna be additional phosphorus coming in.
(18:00):
And so there's likely going to be some
collaboration
between
drinking water and wastewater sides of utilities
to get a better understanding of this, to
optimize it further, and to prepare for potential
changes on effluent management. Implementing changes related to
the lead and copper rule won't be simple
for water utilities,
(18:20):
though Chance said he expects preliminary measures to
begin soon. It's still gonna take a little
time for many of the state primacy agencies
to adapt and implement the rule locally. And
so a year from now, you'll probably still
have many utilities across The US waiting on
their state primacy agencies to roll out the
(18:40):
rule within their state. That said, I fully
anticipate utilities
everywhere
to begin
working on some of the major elements of
the rule, including the lead service line inventory
and then
getting their field staff accustomed to and trained
on the new recommendations on sampling and monitoring.
That said, the lead and copper rule has
(19:02):
experts like Chance digging into the details to
be prepared to provide guidance. I think the
the biggest thing that people in our industry
can do to help our utility clients and
to help these water systems
address the new rule is at the planning
level right now. And so the rule is
huge. It's nearly 300 pages. And as I
(19:23):
said, there are six major elements, and each
of those elements inherently have a wide range
of requirements and things that utilities are gonna
need to understand. And so I think that
it's upon the consulting industry to help educate
utilities,
help understand the requirements of the rule, help
benchmark their current practices,
and then identify the steps steps that are
(19:44):
gonna need to be taken in a systematic
and intentional way
to reach compliance
for the new rule when it's required.
For more information on this podcast, visit hdrinc.com/speakingofdesign.
You'll find links to pictures, articles, and more
information about this project.
If you like what you heard, be sure
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