Lead and copper enter drinking water mainly from corrosion of lead and copper containing plumbing materials. While use of lead in plumbing materials has been banned for more than a quarter century, the release of lead into drinking water remains a serious concern.
Environmental lead exposure is decreasing; children’s blood lead levels are a fraction of previous levels. As efforts continue to reduce lead exposure from all sources, there is an increasing focus on what more the water sector can do to assist the communities they serve reduce lead.
The USEPA published a final rule revising the existing Lead and Copper Rule (National Primary Drinking Water Regulations: Lead and Copper Rule Revisions) in the Federal Register on January 15, 2021.
To allow for review of the January final rule under Executive Order 13990, EPA delayed the “effective date” of the revisions to December 16, 2021 and the initial compliance date to October 16, 2024. On December 17, 2021 EPA summarized the conclusions from its review and described next steps. Those steps are:
EPA allowed the revised January 15 rule effective date to stand (December 16, 2021), as does the initial compliance deadline (October 16, 2024)
EPA intends to propose and finalize further revisions to the January 15 rule before the October 16, 2024 compliance date
EPA is preparing guidance for systems preparing lead service line inventories
The January 15 rule made significant changes to the existing LCR, including requiring water systems to:
Develop lead service line inventories and lead service line replacement plans that include lead service line replacement prioritization and a strategy for funding to accommodate customers unable to pay for lead service line replacement
Deliver public notification within 24 hours of a lead action level exceedance (90th percentile lead concentration is greater than 15 µg/L)
Provide customers individual lead observations greater than 15 µg/L within three days or less
Evaluate corrosion control and initiate lead service line replacement if 90th percentile lead concentration is greater than 10 µg/L)
Use new homeowner sampling protocol which includes a 5th liter sample if a home with a lead service line is being sampled during compliance monitoring Identify and address factors contributing to compliance monitoring observations above 15 µg/L
Engage individual property owners in achieving full lead service line replacement in the course of ongoing construction and in order to meet lead service line replacement objectives following a lead trigger level or action level exceedance
Sample for lead in drinking water at all elementary schools and child care facilities in their service area
Begin now to take steps to meet compliance deadlines. Make sure your system has a lead service line inventory you can trust, that meets the January 15 rule requirements, and that you have a data system that supports developing the current inventory, improving the inventory over time, using the inventory to comply with rule requirements, and system planning, operational, and communication activities.
In order to meet rule requirements that take effect in 3 – 4 years (e.g., compliance sample pool and protocol, lead service line replacement and lead education) water systems need to organize available information and develop a plan to assure compliance when the rule provisions take effect.
Develop a lead service line inventory and strategy to remove lead service lines. Lead service lines are a large potential source of lead in drinking water. The Lead Service Line Replacement Collaborative provides an introduction to building a community-based approach to lead service replacement. Replacing lead service lines completely will require a shared effort with customers, local government leaders, and numerous other local agencies.
Importantly, water systems will want to begin evaluating how to utilize federal, state, and other funds to facilitate full lead service line replacement throughout their service area including service lines providing water to households that are financially challenged.
Talk about lead with your customers. Every water system has a story to tell. Customers want to know about the likely sources of lead present in thier community, what the system is doing to control corrosivity, and options for customers concerned about lead to take additional actions. Suggestions on how to communicate effectively are available in AWWA’s Lead Communications Toolkit.
Review and refine current corrosion control practice. All systems serving more than 50,000 persons have a formal corrosion control treatment program. All other systems are managing their supplies, perhaps with active treatment measures, to reliably comply with the current LCR action levels. Understanding and modifying corrosion control takes careful study and evaluation.
AWWA Lead Resources
ANSI/AWWA C810, Replacement and Flushing of Lead Services Lines
EPA Final Rule implementing Section 1417 of the Safe Drinking Water Act: Prohibition on Use of Lead Pipes, Solder, and Flux
3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities