AWWA’s Corrosion Control Implementation Framework

Corrosion control has long been a cornerstone of public health protection in drinking water systems. With the release of the Lead and Copper Rule Improvements (LCRI), the industry is entering a new phase, one that requires utilities to revisit how corrosion control treatment (CCT) is evaluated, optimized, and implemented to comply with new requirements, such as the revised 10 microgram per liter action level. Many systems are asking the same questions: Where do we start, and how do we know we’re taking the right steps?

To help answer these questions, the American Water Works Association (AWWA) has released the Corrosion Control Implementation Framework. This comprehensive Framework, prepared by Carollo’s Caroline Russell and Jerry Yan in collaboration with Cornwell Engineering Group, provides a clear, step-by-step roadmap for utilities navigating corrosion control under the LCRI and beyond. The Framework was developed with input from federal and state regulators, utilities, and industry experts.

Practical Roadmap for Corrosion Control Under the LCRI

The Framework is designed to support water systems that need to implement, optimize, or reoptimize corrosion control treatment for lead and copper. While it aligns closely with the new LCRI requirements, its usefulness extends beyond compliance alone. As the framework explains, its goal is to provide “concise and clear guidance on the steps and approach to optimize or re-optimize CCT for their system based on site-specific characteristics and drivers.”

Importantly, this is not a theory-heavy document or a prescriptive design manual. Instead, it focuses on helping utilities identify and implement system-specific steps leading to an informed decision on CCT. The Framework is also intended to support state regulators overseeing corrosion control activities as utilities prepare for the LCRI compliance deadline on November 1, 2027.

Supporting Lead and Copper Rule Improvements (LCRI) Compliance

One of the Framework’s core strengths is its direct attention to the practical implications of the LCRI. The updated rule introduces new expectations around lead action levels, sampling protocols, and corrosion control decision-making. Rather than replacing existing EPA guidance, the framework fills a critical gap while federal updates are still in development.

The document clarifies when a corrosion control study (CCS) is warranted, what level of evaluation is appropriate, and how systems of different sizes and characteristics can tailor their approach. It also recognizes that not every system requires the same depth of testing. In some cases, a desktop evaluation may be sufficient; in others, more involved testing, such as pipe-loop or pipe-rig studies, may be required.

Making Informed, System-Specific CCT Decisions

The Framework emphasizes that optimal corrosion control treatment is not one-size-fits-all. Under the LCRI, “optimal” means minimizing lead and copper at the tap while avoiding unintended consequences elsewhere in the system, such as impacts to other water quality goals or regulatory compliance.

By accounting for system size, source water characteristics, existing infrastructure, and operational considerations, the Framework helps utilities weigh tradeoffs and avoid unnecessary testing or treatment changes. It also reinforces that corrosion control is one part of a broader distribution system strategy that includes operations, maintenance, and water quality management.

Why the Corrosion Control Implementation Framework Matters for Utilities Today

As utilities prepare for LCRI implementation, the Corrosion Control Implementation Framework offers timely, practical guidance grounded in real-world experience. It reflects a decade of research and lessons learned since EPA’s 2016 corrosion control guidance and provides a flexible roadmap that utilities can adapt to their specific conditions.

The Framework is freely available on AWWA’s website and serves as a valuable reference for utilities, regulators, and consultants alike.

Read the full Corrosion Control Implementation Framework to explore the step-by-step guidance and learn how it can support informed corrosion control decisions under the LCRI and beyond.