As you are all aware by now, Congress passed the Reduction of Lead in Drinking Water Act on January 4, 2011,with an effective date of January 4, 2014. The Act amends the statute’s definition of “lead free” found in section 1417(d)(1)42 U.S.C. 300g-6. As of Jan. 4, 2014, lead free will mean “not more than a weighted average of 0.25 percent leads when used with respect to the wetted surfaces of pipes, pipe fittings, plumbing fittings, and fixtures.” Many small and rural communities have existing purchased inventories of drinking water system components that will be prohibited for use after 1/4/14.
NYRWA wants to make all of you aware that there are exemptions to the new standard. Section 1417(a)(4)(b) exempts, among other things, service saddles or water distribution main gate valves that are 2 inches in diameter and larger. It was previously thought that hydrants were also exempt from the reduced lead provisions of the Act because they are used exclusively for nonpotable services. In fact, several months ago, ANSI/NSF published a voluntary test protocol to certify fire hydrants to Annex G and 372 inside the hydrant shoe with the main valve closed, which is the normal condition of the hydrant. However, on Tuesday of this week, the US EPA published a guidance document providing answers to questions posed by the AWWA pertaining to the upcoming implementation of the Act. Unexpectedly, EPA determined that hydrants must meet the reduced lead standards in the Act because “fire hydrants can be, and are, used in emergency situations to provide drinking water.”
This past week all the national water associations held a very productive and unified meeting on EPA’s recent ruling that hydrants are covered under the new lead free standards (increasing cost and requiring retro-fitting). There was unanimous agreement among the group to provide EPA with a statement urging EPA to reconsider the ruling in light of identified opportunities for EPA to modify their existing policy to provide some relief.
So to be perfectly clear on the current hydrant issue, you can install your existing inventory prior to January 4, 2014, because they are compliant with the existing law through this date. However, after January 4, 2014, you will no longer be able to install your old inventory, unless retrofitted to meet the reduced lead standards. We urge all systems with hydrants that do not meet the new reduced lead standards to contact your hydrant representatives.
Pat Scalera, CEO NY Rural Water Association