What Are the Major Requirements of the EPA’s Lead and Copper Rule Revisions?
Getting Your System Ready Checklist
There is a lot to unpack with the LCRR. Here are 8 things all water systems must complete before January 2024 to meet the new requirements:
- Develop an inventory of all service lines, including public-side and private-side materials, and make it publicly available.
- Verify as many service lines of unknown material as possible because unknown materials are classified as lead service lines (LSLs) unless evidence proves otherwise.
- If your system has lead service lines, prepare a lead service line replacement plan.
- Revise sampling protocols and communications for 5th liter sampling if there are LSLs in your system.
- Revise your sampling pool location to align with the new sampling tiers.
- Prepare a sampling plan and communications for lead testing in schools.
- Review your corrosion control treatment by evaluating 5th liter LSL samples and re-optimize if needed.
- Prepare your public notifications and sample notifications and have them ready to meet the quick response times.
5th Liter Sampling
Research has shown that the major contributor to lead in drinking water is typically LSLs in older homes based on sequential sampling which shows lead contributions from various components in home plumbing. For homes with LSLs, the compliance sample will now be the 1st liter to test copper levels and the 5th liter to test for lead levels to better capture water in contact with the LSL for the stagnation period. This infographic from the EPA helps break down the revised sampling requirements for homes with LSLs. For non-LSLs, the sampling will remain the 1st liter for both lead and copper.
The graph pictured below is a sequential sampling profile (a collection of each liter of water from the tap to the main) showing a common profile for homes with LSLs. As it shows, although the 1st liter may be below the 15 parts per billion (ppb) lead action level, that may not necessarily mean the 5th liter will be below 15 ppb. Through our sampling experience, we have found 5th liter samples to have a significantly higher lead concentration in LSLs. Consequently, the 5th liter requirement may result in higher lead levels for compliance purposes.
Adding a 10 ppb Trigger Level
The revised LCR adds a new lead trigger level of 10 ppb. The trigger level is based on a 90th percentile calculation, like the 15 ppb lead action level. If exceeded, actions such as corrosion control re-optimization treatment studies and LSL replacements at a goal-based annual rate are required for most systems.
Defining a Lead Service Line
Another major change is the definition of a “lead service line." For clarity to customers, the EPA decided not to classify galvanized and unknown service lines as “lead service lines.” Instead, galvanized service lines that are, or were formerly, downstream of any lead pipes will be classified as “galvanized requiring replacement.” Service lines of undocumented materials that could potentially be lead—for example, installed prior to any local or federal lead ban—will be classified as “lead status unknown.” Both the “galvanized requiring replacement” and the “lead status unknown” lines will count as lead service lines in a water system’s inventory. Lead goosenecks alone do not count as LSLs. Galvanized service lines downstream of lead goosenecks are not considered LSLs unless there was an LSL previously between the gooseneck and the galvanized pipe.
Galvanized service lines meeting the "galvanized during replacement" description will need to be part of your water system’s replacement plan. Service lines of unknown material that could potentially be lead will need to be verified to be removed from the LSL inventory list. An annual notification to all customers with lead, galvanized and unknown service lines will be required until the line is removed or verified.
Reclassifying Sampling Tiers
The sampling tiers have also been reclassified and now require systems with LSLs to sample only homes with LSLs, which means the sampling pool will consist of all 5th liter samples from LSLs for lead compliance. If there are not enough Tier 1 (single-family) and Tier 2 (multi-family) LSLs in the system to complete the pool, water systems will be required to sample from galvanized service lines, a new Tier 3 level. Sample sites with copper interior plumbing with lead solder have fallen to Tier 4. There is no longer a distinction between lead solder in copper plumbing before or after 1983 per the LCR revisions.
Testing Water at Elementary Schools and Childcares
Water systems are now required to conduct lead in drinking water testing and public education at 20% of all elementary schools and 20% of licensed childcare facilities each year with the goal of reaching all elementary schools and childcare facilities in 5 years, rotating 20% each year. Sample results and public education are required to be provided to the schools, but the results do not count towards compliance sampling.
Facing New Challenges
Combining the 5th liter sample requirement for locations with LSLs and the 10 ppb lead trigger level will pose challenges for many utilities. In 2024 when the compliance with the LCRR will be mandatory, we anticipate most water systems, especially those with lead or galvanized service lines, will be required to go on 6-month monitoring periods, regardless of previous “optimized” status, since systems will now need to meet compliance with the revised sampling protocols. For those with LSLs, previous sampling rounds will not be able to be used to show compliance unless 5th liter samples were taken.
Changes to treatment processes, practices, or introduction of new sources of supply will also trigger a corrosion control treatment study, likely including a pilot-scale loop study, for the new conditions.