EPA Lead and Copper Rule Changes


The EPA has posted proposed revisions to the Lead and Copper Rule. The deadline to submit a public comment is February 12, 2020.

WQA has submitted comments and recommends members review the rule revisions and submit their own comments.

Main changes that effect the water treatment and filtration industry:

  • The action level is remaining 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 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.

    • For Community Water Systems

      (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

(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.


  • 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 3 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.

 

Resources:

WQA Submitted Public Comment

EPA Lead And Copper Rule Proposed Revisions Docket to Submit Public Comments: https://www.regulations.gov/docket?D=EPA-HQ-OW-2017-0300

EPA Lead and Copper Rule Revisions: https://www.regulations.gov/document?D=EPA-HQ-OW-2017-0300-0001