Lead and Copper Rule (LCR) monitoring is becoming more onerous and expensive for utilities for several reasons. This report is designed to assist utilities in addressing LCR monitoring issues including variability in data, shrinking sample pools, increasing cost of monitoring programs, and the differing needs of utilities verifying optimization versus those trying to achieve optimization in the first place. This report focused on the needs of utilities, who, previously optimized for corrosion control, are now faced with a change in treatment or source water. The objectives of this report were to: develop a statistically valid alternative to home tap sampling, develop an on-line monitoring tool and methodology to track corrosion changes, and assess regulator interpretation of the LCR Minor Revisions and their possible acceptance of potential alternative tools for previously optimized utilities.
The project approach was divided into five tasks: (1) a survey of state primacy agencies to identify barriers to alternative compliance strategies, identify agency expectations of alternatives, and determine the willingness of primacy agencies to accept alternative protocols; (2) utility case studies describing optimization experience; (3) development of a statistically sound alternative in-home tap monitoring protocol; (4) development of an on-line, real-time corrosion monitoring method and hardware; and (5) field testing of both protocols for viability of utility application and limitations.