A Look at Lead and Copper Rules
A message from MWWA President and Tighe & Bond Sr. Project Manager Jeffrey Faulkner in the organization’s August 2022 Newsletter, Edition No. 223
Lions and tigers and bears, oh my!! PFOA, PFOS, and LSLs stop making me cry!! The current alphabet soup of today’s water professionals creates headaches, operational challenges, and ultimately huge price tags.
The Revised Lead and Copper Rule requires water systems to take a hard look at not only the water service pipe materials that they typically own, from the water main to the curb, but also from the curb to the house, which the customer usually owns. Water systems are required to complete water service material inventories by October 16, 2024.
The main goal of these inventories is to determine where there are lead service lines (LSLs) in whole or in part. The complication is that water system service pipes can be 50, 75, or even 100 years old. Records of what material a service pipe is made of or how it was constructed long ago can be inconclusive or nonexistent. A variety of methods can be employed for researching pipe materials, but most methods are time-consuming and labor intensive. The earlier you start your process, the better off you will be. Good luck to all.
And then on June 15th, 2022 the EPA released updated interim health advisories on Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS).
Drinking water health advisories provide information on contaminants that can cause human health effects and are known or anticipated to occur in drinking water. They are non-enforceable.
The new PFOA Interim Updated Lifetime Health Advisory is 4×10-9 mg/L or 0.004 parts per trillion. This can also be noted as four parts per quadrillion. Four parts per quadrillion is four parts per 1,000,000,000,000,000 parts.
The new PFOS Interim Updated Lifetime Health Advisory is 2×10-8 mg/L or 0.02 parts per trillion or 20 parts per quadrillion.
These new Health Advisories apply to all populations. The prior EPA Health Advisory level was a combined PFOA and PFOS level of 70 parts per trillion for only sensitive sub-populations.
This reduction from 70 parts per trillion to 0.024 parts per trillion (0.004 ppt + 0.02 ppt) represents more than a 2,900-fold combined reduction.
The new Health Advisory levels are below analytical detection limits; therefore, no water supplier, including bottled water suppliers, can currently prove their water is below the Health Advisory levels. This causes undue stress and unnecessarily reduces confidence in water systems.
While we all applaud the protection of public health, the infinitesimal numbers are simply jaw-dropping. I never thought I would use the word quadrillion in a professional setting. I thought it would be reserved for when I was doing my best Austin Powers imitation. As a matter of perspective, four parts per quadrillion is the equivalent of 1 milliliter in 100,000 Olympic-sized swimming pools.
As we move forward on this PFAS journey with the EPA eventually setting Maximum Contaminant Levels (MCLs), I encourage all to play an active role in the discussion to help shape the future with water work professionals being considered a steward of public health.