The working group of the National Drinking Water Advisory Council (NDWAC) established to review potential revisions to the Lead and Copper Rule (LCR), held its third meeting on September 18 and 19. This meeting focused on sampling protocols and public education and outreach.
One of the major themes discussed at the meeting was the need to separate lead and copper into their own, distinct sections within the LCR construct. Because the problems of copper corrosion are limited to new piping in corrosive water environments, consensus appears to be coalescing around a “binning” of water systems based on basic water chemistry parameters. Those systems demonstrating that their water is non-corrosive, would not have any further copper monitoring obligations since release is not expected. Systems that could not make a demonstration of non-corrosiveness, would need to take further actions, including consideration of adding corrosion control treatment and outreach to anyone installing new copper piping.
For lead, substantial discussions revolved around separating monitoring and resulting actions for corrosion control from household monitoring. The argument was made that water quality parameter monitoring in the distribution system was the best way to monitor and adjust corrosion control practices. Monitoring in the home was starting to be discussed more in terms of sentinel monitoring to identify those homes that may require follow-up actions from a public health perspective. Water utility representatives on the subgroup strongly suggested, however, that any follow-up to in home monitoring needs to be turned over to the public health department or other agency that has the knowledge, and more important, the jurisdiction over home health interventions.
There is certainly no consensus yet from the workgroup on a path forward, but the thinking among the workgroup members seems to be moving in the direction of suggesting new paradigms for both copper and lead regulation in drinking water that goes beyond simple, minor tweeks to the existing LCR.
Two additional working group meetings are anticipated, one covering lead service line replacement and a final meeting to pull together recommendations for presentation to the full NDWAC during their Spring 2015 meeting. Based on that schedule, recommendations from the full NDWAC are not expected to reach the EPA Administrator until well into 2015. Following the submission of NDWAC recommendations, development of further analyses and typical review processes are likely to push the proposal of a revised LCR into late 2015 at the earliest.
AMWA member Robert Steidel, City of Richmond Virginia Director of Utilities, continues as a member of the NDWAC workgroup reviewing potential revisions to the LCR. AMWA staff is also attending all meetings and will provide continual updates on the process.