(March 13, 2018) - NACWA submitted comments to EPA on March 8 regarding the Agency’s preliminary efforts to make long-term revisions and updates to the Lead and Copper Rule (LCR). Although the LCR is primarily a drinking water issue that impacts public water systems under the Safe Drinking Water Act (SDWA), NACWA is urging EPA to consider the impacts to municipal clean water utilities that are regulated under the Clean Water Act (CWA).
Initially, NACWA is concerned that EPA will take a “one-size-fits-all” approach in determining corrosion control treatment, rather than allow states and public water systems (PWSs) the flexibility to select the best corrosion protection method for their site-specific water quality needs and infrastructure characteristics. The Association is also concerned if PWSs increase their application and/or concentration of phosphate-based inhibitors for corrosion control, POTWs must also increase their efforts and advanced treatment processes—at great capital costs—to remove the added phosphorus.
NACWA believes EPA has a unique opportunity as the Agency commences long-term LCR revisions to view this critical regulatory issue through the lens of a holistic, one-water approach that cuts across both the SDWA and CWA. The municipal clean water community is committed to addressing excess nutrient loading, but EPA is potentially requiring drinking water systems to increase their dosage of phosphorus-inhibitors and requiring wastewater plants to meet stringent effluent limits for phosphorus.