EPA Lead and Copper Rule Changes
The U.S. Environmental Protection Agency in December of 2021 moved forward with the implementation of the Trump Administration’s Lead & Copper Rule Revisions (LCRR). The agency’s review of the rule highlighted notable areas for further support including Lead Service-Line Replacement (LSLR); Re-evaluation of compliance sampling; Action & Trigger Levels; and analyzing the LCRR implementation through an environmental justice perspective.
Although EPA intends to propose further revisions to the rule through the Lead and Copper Rule Improvements (LCRI), the agency’s implementation of the LCRR will bring significant changes that affect the water treatment industry.
Main changes that affect the water treatment and filtration industry:
- The action level remains at 15 parts per billion, and a new trigger level has been created at 10 parts per billion to require additional planning, monitoring and treatment.
- Allows Community Water Systems serving 10,000 or more people and all Non-Transient Non-Community Water Systems to elect to maintain point-of-use devices certified to remove lead in place of corrosion control treatment.
- To address potential line disturbance after a lead service line replacement, partial lead service line replacement, or replacement of the water meter or gooseneck, pigtail, or connector, systems will provide a certified pitcher to remove lead for up to three months and conduct a follow-up test.
- Homes with lead service lines or unknown material will receive an annual letter from the system explaining its line replacement program and other options.
For Community Water Systems Electing to Maintain POU Devices:
(i) A community water system must install a minimum of one POU device (at one tap) in every household or building in its distribution system.
(ii) The POU device must be certified by the American National Standards Institute to reduce lead in drinking water, and
(iii) The POU device must be maintained by the water system to ensure continued effective filtration, including but not limited to changing filter cartridges and resolving any operational issues.
(iv) The community water system must monitor one-third of the POU devices each year and all POU devices must be monitored within a three-year cycle. First-draw tap samples collected under this section must be taken after water passes through the POU device to assess its performance. Samples should be one-liter in volume and have had a minimum 6-hour stagnation time. All samples must be at or below the lead trigger level. The system must document the problem and take corrective action at any site where the sample result exceeds the lead trigger level.
For Non-Transient Non-Community Water Systems Electing to Maintain POU Devices:
(i) A non-transient non-community water system must provide a POU device to every tap that is used for cooking and/or drinking.
(ii) The POU device must be certified by the American National Standards Institute to reduce lead in drinking water and
(iii) The POU device must be maintained by the water system to ensure continued effective filtration, including but not limited to changing filter cartridges and resolving any operational issues.
(iv) The non-transient non-community water system must monitor one-third of the POU devices each year and all POU devices must be monitored within a three-year cycle. First-draw tap samples collected under this section must be taken after water passes through the POU device to assess its performance. Samples should be one-liter in volume and have had a minimum 6-hour stagnation time. All samples must be at or below the lead trigger level. The system must document the problem and take corrective action at any site where the sample result exceeds the lead trigger level.
Resources:
WQA-Submitted Public Comment (February 2020)