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National Primary Drinking Water Regulations: Lead and Copper Rule Revisions

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League of Women Voters filings
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League of Women Voters filed 1 comment on this docket between Dec 31, 2019 and Dec 31, 2019. 95 other organizations filed here. The comment window closed 911d ago.

What League of Women Voters filed (1)

Dec 31, 2019· Comment submitted by Nancy J. Miller, Co-President, and Louise Wilkerson, Co-President, League of Women Voters of Metro Saint Louis (LWV)· EPA-HQ-OW-2017-0300-0957

The League of Women Voters of Metro Saint Louis, using our Natural Resource position to "promote an environment beneficial to life through the protection and wise management of natural resources in the public interest" and our water resource positions recognize that the new regulations do improve the National Drinking Water Act. However, the rule revisions do not adequately address the lead issue, including the need for full lead line replacement. The new requirements do modestly improve the National Drinking Water Regulations: 1. Local utilities are required for the first time to test for lead in childcare facilities and schools. It is not clear, however, whether all schools and day cares and all faucets and fountains therein must be tested nor how often. St Louis City is now testing children younger than 5 years old who live in the city. Of the 46% of children in this age range, 0-72 months, who were tested, 30% already had a blood lead level of at least 5. (When children with high levels are identified at a young age, mitigation is more effective.) 2. EPA's proposal will require water systems to inventory lead in their distribution system, report this information to state agencies, and to make these findings available to the public. 3. The proposed regulations will require that all test samples be taken at homes with lead service lines, compared with only half under the current rule. 4. When the utility finds elevated lead levels, they will need to notify homeowners within 24 hours. 5. There is a strengthening of the lead testing protocols to detect lead levels in tap water, including the elimination of pre-flushing of water lines and banning other methods that tend to minimize detection of lead. 6. The proposal does establish a lower "trigger level" of 10 ppb to compel water system administrators to identify actions to reduce lead levels The League does find that the revisions do not go far enough to ensure that every American has access to clean and safe drinking water. 1. The revised proposal does not set one enforceable standard for lead (maximum contaminate level [MCL]). In addition, the proposal does not change the standard when officials need to act. The current requirement to find and fix sources of lead when a sample exceeds 15 parts per billion ppb (Lead Action Level) remains, even when it is known that no amount of lead is safe. If no MCL is set, then EPA should reduce the Lead Action Level to 5 ppb (the Canadian at-the-tap standard and the proposed European Union standard) to insure safe drinking water. However, the draft rule revisions do not adequately address the lead issue, including the need for full lead line replacement. 2. Lead service lines are the largest sources of lead at the tap, yet the proposal stops short of prohibiting partial lead service line replacements, which can elevate lead levels. The EPA's proposed revision also delays the replacement of the 6 to 10 million lead service lines that remain underground around the county. With the current rule, water utilities have about 13 years to replace the lead service lines that have lead levels above the EPA's Action Level of 15 parts per billion (they must replace 7% of lead service lines each year until the lead levels no longer exceed the 15 ppb standard). The new proposed regulations weaken this by permitting water systems to replace their lead service lines over 33 years (they are required to remove 3% of their lead service lines each year for as long as they exceed 15 ppb). There should be an enforceable timeline of no longer than 10 years to fully replace all lead service lines. The recent lead water crisis in both Flint, MI and Newark, NJ were the result of deliberate evasion of federal rules that are seldom enforced, and the lack of an enforceable maximum contaminate level. The success of proposed updated regulations will require regulatory infrastructure investment by the local, state, and federal governments. This will ensur…

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Abstract

The objective to the long-term revisions to the Lead and Copper Rule is to improve public health protection while ensuring effective implementation.

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