AWWA JAW30326

This article discusses the content and implications of new lead and copper regulations under the Safe Drinking Water Act. The new rule applies to all community water systems and all nontransient, noncommunity water systems. The interim MCL for lead is replaced by "action levels," which trigger prescribed treatment techniques. The new rule contains: maximum contaminant level goals for lead and copper; treatment techniques that include corrosion control, water treatment, and lead service line replacement; monitoring, public notification, and record keeping; and administrative facets such as variances and compliance schedules. Eleven tables provide specific requirements of the rule. Treatment techniques are required when lead exceeds an "action level" of 0.015 mg/L or copper exceeds 1.3 mg/L. All large water systems are required to conduct corrosion control studies unless they can show that corrosion control has been optimized. Small systems are considered to have optimized corrosion control if they do not exceed the "action levels" during each of two consecutive six-month monitoring periods. Utilities that continue to exceed action levels, even after instituting corrosion control and source water treatment, must replace lead service lines as needed. In addition to monitoring for lead and copper, all large water systems--and small or medium systems that exceed the "action levels"--must monitor water quality for additional constituents. Legal disputes may arise on three fronts: environmentalists who want to see an MCL for lead at the customer's tap; utilities who see water quality monitoring at the customer's tap as an improper extension of authority beyond the public water system; and disputes over who owns and must replace certain portions of lead service lines. Includes 6 references, tables.