Document EvZMmvz6Bem56yk1GJ5eN2XN
Lead
Evaluation/acceptance of other technologies in place of lead service line replacement
o recent inquiry by consulting firms looking for approval of insitu technologies to serve in place of lead service line replacement, with costs being the driver (LSL replacement in a large community system is not cheap)
o Rules do not allow for this "replacement", however, perhaps additional study by EPA into these technologies (effectiveness, longevity, effects on water quality) could decide the fate of such technologies as it pertains to the Pb/Cu rules and required LSL replacements
Partial Lead Service Line Replacement versus No Replacement
It is widely accepted that full lead service line replacements are more effective in limiting lead exposure to a customer than partial lead service line replacement. Additional study into the effectiveness of partial lead service line replacement (to the property line of a property) when compared to not replacing the lead service line would be helpful in answering the question of whether states should only be allowing full lead service line replacements for protectiveness of the consumers.
Manganese
Cost-effective removal treatments for small systems
o With the expansion of Mn monitoring in Ohio, many more systems are being asked to install treatment
o Small community and non-transient non-community systems above standards, and transients with very high Mn levels in raw water (> 1.0 mg/L) have difficulty absorbing those treatment costs.
o With the ever-growing issue of Mn in Ohio, research into possible lower-cost treatment options for smaller-volume water producers would be helpful
Brominated DBFs
Ohio EPA has seen exceedances of TTHM MCL in PWSs located in NW and particularly SE Ohio (primarily small community systems).
Natural or anthropogenic bromide levels in source water (GW and SW) range from 80-850 ppb. Primary species forming in finished water is tribromomethane (Bromoform). PWSs are having a difficult time mitigating with best available treatment technologies (Aeration) due to the
physical and chemical properties of the brominated species. Ohio EPA has discussed this issue with Dr. Mike Elovitz at ORD-Cincinnati to seek technical input on
treatment technologies and current science. Ohio PWSs presenting regulated contaminants that difficult to mitigate present a prime opportunity for
collaboration between US EPA, Ohio EPA, and PWSs.
Technical Assistance and Treatment Technologies for Small Community Systems:
Assist states in acceptance of treatment technologies that are: implemented using existing infrastructure, require low capital investment, and minimal operational knowledge, for the treatment of emerging contaminants.
Guidance and pilot demonstrations for biological treatment and conversion of existing treatment to biological treatment.
Sierra Club v. EPA 18cv3472 NDCA
Tier 10
ED 002061 00175912-00001