During a November 18 conference call with EPA, the NDWAC laid out its initial recommendations on potential revisions to the LCR. The NDWAC recommendations draw on the findings of EPA’s Science Advisory Board (SAB) as outlined in their September 28, 2011 evaluation of the effectiveness of partial lead service line replacement (PLSLR) for reducing lead exposure (http://amwa.net/sabpbreport). The SAB report reviewed studies that found that water lead levels, and subsequently, customers’ blood lead levels, actually increased in the short term following PLSLR. Drawing largely from the SAB conclusions, the NDWAC voted to recommend that PLSLR be removed as a requirement under the LCR. Going one step further, the NDWAC also voted to recommend that full lead service line replacements also not be required under the LCR, again due to concerns of possible short-term lead level spikes following service line replacements.
Alarmed by the potential exposure risks, and because any rule change would take some time, the NDWAC made the additional recommendation that EPA immediately communicate to drinking water authorities that they should not enforce the current LCR service line replacement requirements starting immediately. Additional recommendations were made to enhance public notification when lead service line replacements are carried out due to required maintenance and repair.
Removal of any requirements to replace lead service lines (partial or full) would mark a significant overhaul in the LCR regulation, which currently requires lead service line replacement in response to exceeding certain action levels. EPA has not made any public response to the NDWAC recommendations at this point as they await the official submittal of the NDWAC recommendations. Discussions at the December 15 NDWAC meeting indicate that the final recommendations will be in line with those recommended during the November conference call, with submission slated for before the end of the year.