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 released its final rule revising the Lead and Copper Rule on December 22, 2020. The rule will not be official until it is published in the Federal Register.
EPA proposed revisions to the LCR November 13, 2020. The proposed rule drew on a development process that began in 2004 with the Lead Action Plan. A white paper EPA distributed in October 2016 provides an overview of the issues being considered in the rulemaking.
In finalizing the rule, EPA made significant changes to the existing rule, including requiring water systems to:
1. 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
2. Deliver public notification within 24 hours of a lead action level exceedance (90th percentile lead concentration is greater than 15 µg/L)
3. Provide customers individual lead observations greater than 15 µg/L within three days or less
4. Evaluate corrosion control and initiate lead service line replacement if 90th percentile lead concentration is greater than 10 µg/L)
5. Revise the LCR homeowner sampling protocol to include a sample representative of the 5th liter when lead service lines if a home with a lead service line is being sampled.
6. Identify and address factors contributing to compliance monitoring observations above 15 µg/L.
7. 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.
8. 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. 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.
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 your 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 take careful study and evaluation.
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.