FLOW-LINER SYSTEMS, LTD.

Environment/Superfund

Issues relating to use of certified, trenchless, structural lining technology to rehabilitate drinking water mains are available options for water systems asset management plans. Issues relating to use of certified Polyethylene terephthalate (PET) liners to rehabilitate service lines. Issues relating to the inclusion of all drinking water technologies that effectively extend integrity and service life of aging deteriorating drinking water conveyance systems in a comprehensive infrastructure package. Issues relating to EPA clarification in lead and copper rule that certified drinking water service line rehabilitation technologies are available options for water systems lead service line replacement plans. asset management plans. Issues relating to a 2016 report on effectiveness of lining lead service lines in Louisville, KY in 2008. Issues relating to the cost-effectiveness of trenchless technology concluded by EPA in 2012 report on Cleveland, OH project. Issues relating to EPA and Water Research Foundation evaluation (2017) of polyethylene terephthalate (PET) lining of lead service lines. There are needed clarifications in the EPA / Water Research Foundation Evaluation (2017) of polyethylene terephthalate (PET) lining of lead service lines making it clear PET lining is made from Virgin PET not recycled PET. This is needed to pass the stringent NSF-61 Standard. Also, the Grade of PET used in our expandable pressure pipe PET liner is a specific crystalline PET, not Amorphous PET. Issues relating to the lead and copper rule (40 CFR 141.84) including: Requirements for service line replacement under the Safe Drinking Water Act will be defined to include technologies that functionally remove and replace the interface between a service pipe and the water with a new permanent barrier between the water delivered and the interior of the piping. If a material receives proper certifications such as American Society for Testing and Materials (ASTM) F-1216 and National Sanitation Foundation (NSF)-61 and prove that lead contaminants are removed in compliance with the lead and copper rule that material is an approved material for water utilities use. EPA acknowledges and encourages innovation in drinking water technologies that prevent entry of contaminants to drinking water as well as those that remove contaminants from drinking water. EPA provides incentives for innovation and use of environmentally-friendly drinking water technologies. Water utilities engaging with EPA water programs (DWSRF, WIFIA, AWIA) are practicing under open competition and actively considering multiple available certified technologies that meet the goals of protecting public health from drinking water contaminants, are efficient and cost-effective. and lead service line replacement/rehabilitation. Issues relating to pre-publication version of Docket No. EPA-HQ-OW-2017-0300, Lead and Copper Rule and the opportunities it presents for policy discussions on innovative drinking water technologies. Issues relating EPA's role in recognizing demonstrated beneficial technologies that are certified, environmentally-friendly, safe & cost efficient and eliminate contact of drinking water with lead or copper pipes. Adapting to this type of innovation will help alleviate escalating future costs of needed drinking water infrastructure that are passed on to water ratepayers. Issues relating to use of NSF 61- approved class-B semi-structural, non-epoxy coating liner with inside diameters from 1�2" to 2". The technology is an expandable pressure pipe made with virgin Polyethylene Terephthalate (PET), It can be installed in steel, copper, plastic and lead pipes, and in lengths up to 300 ft. and can be used to prevent drinking water from contact with lead and to rehabilitate leaking service lines. Issues relating to use of NSF 61- approved Class IV structural liner for the rehabilitation of drinking water mains. The technology is a fully structural composite material liner that uses trenchless methods to renew the water mains system. The diameter is between 6-to-24 inches and operating pressure is tested at greater than 150 psi. Issues relating to the requirements found at 40 CFR 141.84 for replacement of lead service lines. Issues relating to the 2017 EPA & Water Research Foundation report, Evaluation of Lead Service Line Lining, not listed as a resource in the recently released lead and copper rule revisions Docket No. EPA-HQ-OW-2017-0300. Issues relating to the document, EPA Strategies to Achieve Full Lead Service Line Replacement, published by EPA alongside the Lead and Copper Rule, Docket No. EPA-HQ-OW-2017-0300. EPA should have included the policy discussion in the proposed rule as opposed to a separate document. Issues relating to the definition of Best available technology or (BAT), 40 CFR 141.2. BAT means the best technology, treatment techniques, or other means which the Administrator finds, after examination for efficacy under field conditions and not solely under laboratory conditions, are available (taking cost into consideration). For the purposes of setting Maximum Contaminant Levels for synthetic organic chemicals, any BAT must be at least as effective as granular activated carbon. Issues relating to the addition of definitions for replace and rehabilitate at 40 CFR 141.2 Definitions. Issues relating to the Safe Drinking Water Act (42 U.S.C. 300f et seq. (1974) Section 1459B (a)(2)(ii) regarding the replacement of lead service lines that grants the EPA Administrator authority to determine testing, planning or other relevant activities that identify and address conditions that increase concentrations of lead in water for human consumption. Support EPA strengthening consumer awareness and public education in Docket No. EPA-HQ-OW-2017-0300, Lead and Copper Rule. When EPA strengthens consumer awareness that means informing consumers, ratepayers and homeowners about all drinking water infrastructure technologies, including lining that are available to consumers to reduce lead contaminants in their drinking water. Acknowledge EPA is correct that homeowners need to be engaged with actions to reduce lead levels in drinking water because in most communities homeowners own portions of the lead service line. Support EPA in proposing water systems develop an inventory of LSLs and preparing and submitting a LSL replacement (LSLR) plan. Using trenchless technologies can speed the time in which lead contamination can be stopped and therefore speed up removing the health hazard from public exposure. Issues relating to replacing lead service lines with copper pipes that also will eventually corrode.