Do you know how the proposed Lead and Copper Rule Revisions will impact you?
Posted in: Water
On October 10, the United States Environmental Protection Agency (USEPA) issued a pre-proposal draft of the Lead and Copper Rule Revisions (LCRR). The long-anticipated regulatory proposal included a number of changes that could affect public water systems (PWS). Here’s what you need to know:
1. While the copper requirements under the rule remain essentially unchanged, this is not the case for lead. Though USEPA appears to have decided not to lower the lead action level (AL) from its current value of 15 ug/L, the proposal establishes a new lead trigger level (TL) of 10 ug/L. Based on a system’s size and current corrosion control treatment (CCT) status, exceeding the TL triggers certain actions. For example, a medium-sized system that has not previously established CCT would be required to conduct a CCT study and make a CCT recommendation to their state regulatory agency. That CCT would then be required to be implemented if the system exceed the AL in future sampling.
2. Speaking of sampling, the proposed compliance monitoring requirements increase the focus on single family structures (SFS) with lead service lines (LSLs). Under the current rule, sampling focuses on homes with copper service lines and lead solder installed before 1982, and SFS with LSLs only comprise up to 50 percent of a system’s sampling pool. The proposal would require all sampling be conducted at SFS with LSLs if enough sites exist. The proposal also requires targeted sampling at schools and childcare facilities on a regular basis as a part of its increased focus on public education.
3. Water systems will be required to conduct a complete materials inventory of all service lines within three years of rule implementation and make that information available via a publicly accessible website. In addition, all water systems with LSLs will be required to develop a lead service line replacement (LSLR) plan. It does not require, as had been previously expected, a mandatory LSLR program, though replacement is required when initiated by a customer. However, if a water system exceeds the TL, it must implement LSLR at an annual rate approved by the state regulatory agency. When a system exceeds the AL, it must implement its LSLR at a rate of 3 percent per year. In both scenarios, LSLR can be continued after two consecutive years of monitoring below the TL.
4. Finally, the proposal contains several public education elements, including public education to schools and childcare facilities on the risks of lead in drinking water. While the water system is responsible for conducting the sampling at these facilities, the results are not considered in the water system’s compliance determination. Further, the water system is only required to provide the sampling results to the facility. Neither the water system or school or childcare facility is required to act if results exceed the TL or AL.
So, what can water systems do now to begin preparing for the LCRR?
- Start evaluating your historical data. How are your historical lead and copper monitoring data trending? How might it change if you were sampling from more LSLs? Are you at risk of exceeding the TL?
- Conduct a desktop evaluation of your current CCT. If needed, how might you need to change treatment in the future?
- Do you know if and where your system might contain LSLs? Begin preparing a preliminary service line inventory so you’re ready to select new monitoring locations and understand what your future risks may be.
- Reach out to the local school district(s) and childcare facilities. Have they done monitoring? Begin to coordinate a strategy as to how you will work together to address concerns from parents and the public should testing show high lead levels.
Understanding how the LCRR could impact you will help you avoid future surprises when the rule is made final in approximately one year. Mead & Hunt has helped many communities throughout the country address their most challenging regulatory and corrosion issues and can help you meet your future needs.
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