EPA’s Proposed Lead and Copper Rule Revisions Questions and Answers
Why is the EPA proposing revisions to the Lead and Copper Rule?
The EPA is proposing changes to better protect public health through a holistic approach that focuses on targeting the most impacted areas for lead in drinking water, strengthening treatment requirements, removing lead service lines, increasing sampling reliability, improving risk communication, and protecting children in schools and child care facilities.
Why is the EPA proposing a trigger level for lead in drinking water?
The EPA is proposing to establish a trigger level of 10 ug/L. The trigger level ensures that water systems take a progressive set of actions to reduce lead levels at the tap and are prepared in the event of an action level exceedance. Water systems that exceed the trigger level would have to take steps to improve corrosion control treatment and conduct lead service line replacement.
What are the new proposed requirements for replacing lead service lines?
Systems above 10 parts per billion, the new trigger level, but below the action level of 15 parts per billion would be required to work with their state to set an annual goal for replacing lead service lines. They are also required to conduct outreach to encourage homeowner participation in the system’s service line replacement program. Water systems above 15 parts per billion would be required to fully replace a minimum of three percent of the number of known or potential lead service lines annually. The EPA is proposing that water systems fully replace lead service lines. The EPA is proposing to eliminate current requirements for water systems to only replace the portion of the LSL that is owned by the water system, if any, in situations where customers do not choose to replace the portion of the line that is owned by the customer. Systems would also be required to replace the water system owned portion of the line when the customer notifies them that they have replaced the portion of the line they own.
How and why are tap sampling instructions changing?
Water systems would no longer be allowed to instruct samplers to flush water before the 6-hour stagnation period and then take a sample for lead testing. They would also no longer be allowed to instruct samplers to clean or remove their faucet aerator (i.e. faucet screen) before sampling. Lastly, wide mouth bottles would be used to ensure samples are collected at a flow rate similar to how consumers typically fill a glass of water to drink.
Why is the EPA proposing changes to tap sampling tiering requirements?
The EPA is proposing that sites with lead service lines be prioritized for sampling. Water systems with lead service lines must collect all samples from sites served by lead service lines, if available.
What are the changes to corrosion control treatment (CCT) options in this rule?
The proposed LCRR would improve CCT by requiring water systems that have CCT in place to re-optimize their CCT if the trigger level or action level is exceeded. Water systems that do not have CCT in place would be required to conduct a CCT study if the trigger level is exceeded and would be required to install CCT if the action level is exceeded. Water systems would be required to complete CCT installation regardless of whether they meet the lead action level in subsequent monitoring periods. In addition, CCT would be reviewed by the states regularly during sanitary surveys.
What are the new public education requirements in this proposal?
The proposal builds upon the existing public education requirements with many improvements. Communities will be quickly informed, within 24 hours, of an action level exceedance. Individual households whose tap sample exceeds 15 ug/L will also be informed within 24 hours. Community members would have access to information about lead service lines in their community. Consumers with a lead service line will be annually notified and be provided information about actions they can take to reduce their exposure. New customers would be informed about the presence of a lead service line when they establish new water service. Communities may also experience enhanced collaboration amongst water systems, health departments, and school and child care facility managers to reduce lead in drinking water at schools and child care facilities.
How can I submit comments on the proposal?
EPA is taking public comment on this proposal for 60 days after publication in the Federal Register via http://www.regulations.gov: Docket ID No. EPA-HQ-OW-2017-0300.
What small system flexibilities are in the proposal?
Community water systems serving ≤ 10,000 people and all Non-transient non-community water systems that exceed the trigger level may select their compliance approach to address lead with Primacy Agency approval. Community water systems can choose corrosion control treatment, lead service line replacement or provision and maintenance of point-of-use devices. Non-Transient non-community water systems have the additional option to replace all leadbearing materials (because these systems generally control the plumbing materials to the tap). If the water system subsequently exceeds the lead action level, it would implement the selected compliance approach.
What are the proposed school sampling requirements?
A community water system must conduct lead in drinking water testing at 20% of K-12 schools and licensed child cares in service area every year. Sample results and lead in drinking water education materials must be provided to each sampled school/child care, primacy agency and local or state health department.
When will EPA issue the final rule?
EPA anticipates issuing the final rule in 2020.