Revisions to Lead and Copper Rule
The U.S. Environmental Protection Agency (EPA) released a revised Lead and Copper Rule, marking the first significant changes to the existing rule for the first time in 30 years.
Important differences in the final rule from the proposal include:
  • Requirement that a fifth-liter sample rather than a first-liter sample be used in the LCR monitoring at homes with lead service lines.
  • Revision of the proposed “find and fix” requirements triggered based on individual lead values above 15 µg/L.
  • Clarification of how galvanized iron pipe should be treated in developing inventories and sample plans.
  • After an initial round of lead monitoring in school and childcare facilities, sampling is continued upon request; high schools can also request sampling by water systems.
Additionally, the final rule reflects many of the core elements of the November 2019 proposal, including:
  • A requirement that utilities develop lead service line (LSL) inventories regardless of service line ownership, a necessary first step to eventually create an LSL removal program. Utilities must always pursue full lead service line replacement when disturbing a lead service line and are required to replace the utility-owned portion of a lead service when a customer elects to replace the customer-owned portion of the line.
  • Service lines that must be replaced in full include lead service lines and galvanized iron pipes which have or have had lead pipe installed upstream.
  • Utilities are required to test elementary schools and childcare facilities.
  • The 15 µg/L lead action level (90th percentile lead level) remains unchanged, and there is a requirement for public notification within 24 hours if a system exceeds the lead action level.
  • Corrosion control treatment requirements include a new “trigger level” (a 90th percentile lead level of 10 µg/L), that when exceeded a system that currently employs corrosion control would be required to re-optimize existing treatment. Systems that do not currently treat for corrosion control would be required to conduct a corrosion control study.
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