Enclosed are comments submitted by the American Water Works Association on the Lead and Copper Rule Improvements proposed rule. The comments include eleven appendices. Six of the eleven appendices are copyrighted. Each of the six copyrighted items is clearly marked and submitted as a separate file. Due to file size limitations on Regulations.gov two of the attached appendices required submitting multiple files. Enclosed are the following 1.Cover Letter and Comments 2.Appendix A Implications of the Draft EPA Lead and Copper Rule Improvements: Human Health Risk and Benefits 3.Appendix B Full Lead Service Line Replacement Guidance (WRF 4713) (copyrighted) 4.Appendix C AWWA Comments on Lead and Copper Rule Improvements (EPA-HQ-OW-2017-0300-1012) 5.Appendix D Corrosion Control Treatment Training (copyrighted) 6.Appendix E When and How to Evaluate Corrosion Control Treatment When Conditions Change (WRF 5032) (copyrighted) [4 files] 7.Appendix F Guidance for Using Pipe Rigs to Inform Lead and Copper Corrosion Control Treatment Decisions (WRF #5081) (copyrighted) [2 files] 8.Appendix G Strategies for assessing optimized corrosion control treatment of lead and copper (copyrighted) 9.Appendix H Analysis of Impacts of Corrosion Control Treatment on Lead and Copper Levels over Time 10.Appendix I Comparing the Cost of Bottled Water vs In-Home Filter Provision for a Lead Action Level Exceedance and Review of Filter Cost Estimates for LCRI 11.Appendix J ANSI/AWWA C810 - Replacement and Flushing of Lead Service Lines (copyrighted) 12.Appendix K CDM Smith Final Report. Considerations when Costing Lead Service Line Identification and Replacement.
National Primary Drinking Water Regulations: Lead and Copper Rule Improvements
Activity
American Water Works Association filed 15 comments on this docket between Nov 17, 2022 and Feb 13, 2024. 86 other organizations filed here. The comment window closed 904d ago.
What American Water Works Association filed (15)
Filed as an attachment.
The attached letter is submitted on behalf of the members of the Illinois Section American Water Works Association.
Comments submitted by the Michigan Section of the American Water Works Association
Filed as an attachment.
See attached file for comments respectfully submitted by the California-Nevada Section of AWWA. Thank you for the opportunity to share our views.
Filed on regulations.gov — full text not in the inline record.
Additional file to Louisville Water comments; AWWA comments incorporated by reference in letter. Not sure necessary.
Good Afternoon – please accept the attached comments specific to the LCRI from the Ct Section of the American Water Works Association and the CT Water Works Association. Please contact me should you have any questions. Thank you, Tom.
Comments from the South Carolina Section of the American Water Works Association on the Lead and Copper Rule Improvements
The American Water Works New Jersey (AWWA NJ) Section's Water Utility Council is providing comments on the USEPA Lead and Copper Rule Improvements under Docket ID No. EPA-HQ-OW-2022-0801 via the attached AWWA NJ Section Lead and Copper Rule Improvements Position Paper Document Completed on January 18, 2024. While AWWA NJ supports the USEPA's effort to improve the Lead and Copper Rule and Enhance Public Health, AWWA NJ has several recommendations that will improve the logistics and reduce costs associated with rule implementation and compliance. AWWA NJ represents over 1,300 members who are united in a mission of providing the residents of New Jersey with safe drinking water. Most of New Jersey's major water utilities, both public and investor-owned, are active members along with engineering and environmental professionals and allied industry businesses. AWWA NJ is dedicated to the promotion of public health and welfare and to the provision of drinking water of unquestionable quality and sufficient quantity, where the WUC is tasked with tracking both Federal and State legislation and regulations on behalf of AWWA NJ. Position The AWWA NJ Section supports the initiative to improve the LCR to enhance public health and the use of a treatment technique rather than a maximum contaminant level (MCL). The AWWA NJ comments that the LCRR and LCRI compliance dates have become overly complex and recommends application of a concurrent compliance date of 2028 for both rules to streamline implementation by water utilities. In addition, the WUC recommends consideration of the comments presented in the seven sections listed below. These sections are Lead Service Line (LSL) Inventories and Replacement, Action Level and Trigger Level, Lead and Copper Tap Monitoring, Sampling after Lead Service Line Replacement and Disturbance, Public Education and Outreach, Distribution System and Site Assessment and Corrosion Control-Optimization and Re-Optimization. Many of these comments respond to the EPA's request for comments although not explicitly identified as such. As EPA is aware, the experience of water utilities in the State of New Jersey adds a valuable and unique perspective where the NJ Department of Environmental Protection (NJDEP) has previously promulgated laws that address much of what is included in the LCRI. On behalf of AWWA NJ, thanks in advance for your consideration. Stephen T. Specht, P.E. AWWA NJ Section Chair - Water Utility Council
Filed on regulations.gov — full text not in the inline record.
Filed on regulations.gov — full text not in the inline record.
Filed as an attachment.
The attached is for inclusion in Docket EPA-HQ-OW-2022-0801. The attached are comments summitted by the American Water Works Association October 31, 2022, to the EPA Science Advisory Board regarding consideration of equity in the Lead and Copper Rule Improvements rulemaking.
Abstract
The Lead and Copper Rule Improvements regulation will protect public health from the risks of lead and copper in drinking water.
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See everyone who commented →- American Water Works AssociationTHIS ORG15 filings · confidence 97%
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