Lead and Copper Rule Changes: What are They and How Can You Prepare
DURATION 4 minute read
The Environmental Protection Agency (EPA) published revisions in October 2019 to the Lead and Copper Rule (LCR). The revisions to the 1991 rule propose to change current standards and add multiple new responsibilities for water systems – leaving many questioning how they can prepare for the potential changes.
Water systems that have yet to consider the proposal run the risk of not having the necessary system in place if the changes take effect. It is crucial water systems act now by creating a framework that sets the table for success under these potential new rules.
Listed below is a brief explanation of some of the EPA’s most notable changes to its Lead and Copper Rule:
Reduced Notification Timeframe
One of the most challenging revisions is the proposed change to reduce the customer notification timeframe. Current regulations mandate water systems contact customers within 30 days if a home sample had lead levels greater than 15 parts per billion (PPB). The revisions, however, would reduce the communication window to 24 hours. Per a survey by 120Water, 86% of respondents are concerned about meeting the notification timeline.
Testing Schools and Childcare Facilities
Protecting children from lead exposure is a driving factor behind the EPA’s LCR revisions. If passed, water systems built before 2014 must sample 20% of childcare facilities and schools in their system every year, in addition to providing findings and remediation recommendations for the facilities.
As written, the revisions would not require water systems to test every fixture in a facility serving children; rather, they would only be required to test five fixtures in schools and two in daycare facilities. Despite this, a best practice full-fixture program for facilities serving vulnerable populations is still encouraged.
This is a new challenge for water systems. 89% of respondents said they are concerned about managing a lead sampling program for schools and childcare facilities, per a survey from 120Water. The EPA is currently weighing feedback and is looking to further clarify how water systems can develop a system that effectively manages lead piping in schools and other childcare facilities.
Creating a Lead Service Line Inventory
Another notable change is the requirement that water systems have a lead service line inventory. This “inventory” must be a living document that is available to consumers and state agencies – like a geographic information system (GIS). Customers will also have to be notified annually via mail if they are served by a lead service line.
The good news is there are multiple cities across the U.S with existing models for a lead service line inventory. The City of Cincinnati, for instance, has an online, publicly available lead service line inventory for both public and private lines. The Greater Cincinnati Water Works (GCWW) initiated an Enhanced Lead Program that offers free home lead test kits and financial assistance to help cover a portion of private LSL replacement costs – incentivizing private property owners to replace tainted lines.
The key factor behind the lead service line inventory is gaining a better understating of not only what is in the public-owned side, but what is on the private side – forcing utilities to cross boundaries and work in the private space.
Strengthened Treatment Requirements
The proposal to strengthen treatment requirements will add a trigger level at 10 PPB to conduct a corrosion control study or re-optimize their existing system.
Lead Service Line Replacement
The new Lead and Copper rule opts for complete service line replacement when a customer-owned portion of an LSL is replaced, and when samples exceed 10 PPB. The LCR revisions do however reduce the annual replacement amount from 7% to 3% for those systems that are above 15 PPB. Systems with lead levels between 10 and 15 PPB will set an annual goal for replacement as approved by their state. Systems can no longer “test out” to avoid LSL replacement.
Implementing the EPA’s Lead and Copper Rule Changes
The EPA made its final revisions to the guidelines on December 22, 2020. States with Safe Drinking Water Act primacy will be required to finish updating their lead and copper rules by mid-2022, and, by mid-2023, all water systems in the U.S must identify and submit all lead service lines in their area.