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TRANSCRIPT
Getting to
Unleaded:Challenges and Solutions in
Facilitating the Removal of
Lead Service Lines
MACRUC 22nd Annual Education Conference
“Getting To Unleaded:
Challenges and
Solutions in Facilitating
the Removal of Lead
Service Lines”
Jay L. Kooper
Vice President, General Counsel
& Secretary
Middlesex Water Company
MID ATLANTIC CONFERENCE OF
REGULATORY UTILITIES COMMISSIONERS
22nd Annual Education ConferenceJune 27, 2017
Palsgraf v. Long Island
Railroad
RIDDLE:
When is a water utility legally responsible for the portion of a water service line that it does not own, did not install, has not mapped, cannot find and cannot access?
ACCORDING TO THE DEPUTY ATTORNEY GENERAL OF NEW JERSEY:
If the water utility is “deemed to control” that portion of a water service line (In Re Readoption of N.J.A.C. 14:2. This question now before the Superior Court of New Jersey, Appellate Division).
Getting to
Unleaded:Challenges and Solutions in
Facilitating the Removal of
Lead Service Lines
MACRUC 22nd Annual Education Conference
MID ATLANTIC CONFERENCE OF REGULATORY UTILITIES
COMMISSIONERS
22nd Annual Education Conference
June 27, 2017
“Getting To Unleaded: Challenges and
Solutions in Facilitating the Removal of
Lead Service Lines”
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 9
Typical Inside Meter Installation
Property Line
Utility Ownership
Customer Ownership
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 10
Typical Outside Meter Installation
Property Line
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 11
Typical Investor-Owned System
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 12
Common Municipal System
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 13
Water Line Materials
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 14
Lead Service Pipes
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 15
Lead & Copper Rule Summary
• Action Levels:
– Lead: 15 μg/L
– Copper: 1.3 mg/L (1,300 μg/L)
– Must be exceeded in more than 10% of the sampled
services
– Treatment Technique – NOT A HEALTH-BASED LIMIT
• MCLG for Lead: Zero mg/L
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 16
Treatment & Control
• Corrosion Control
• Partial Elimination
• Full Elimination
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 17
6/27/17 Howard J. Woods, Jr. Assoc. LLC. 18
Getting to
Unleaded:Challenges and Solutions in
Facilitating the Removal of
Lead Service Lines
MACRUC 22nd Annual Education Conference