Question & answer: Lead and Copper Rule revisions.

Editor's Note: In October 2004, the Washington Post ran an article describing how different cities were manipulating test results so that lead levels appeared to be within federal limits. This article prompted the U.S. Environmental Protection Agency to investigate lead-sampling practices and to develop a drinking-water lead reduction plan.

What Is the History of the Lead and Copper Rule?

In 1991, the U.S. Environmental Protection Agency (U.S. EPA) published the Lead and Copper Rule (LCR) to minimize exposure to lead and copper in drinking water. According to U.S. EPA, the LCR has four main functions:

1. it requires water suppliers to optimize their treatment systems to control corrosion in customers' plumbing;

2. it determines tap water levels of lead and copper for customers who have lead service lines or lead-based solder in their plumbing system;

3. it rules out source water as a cause of significant lead levels; and

4. if action levels are exceeded, it requires suppliers to educate their customers about lead and suggests actions they can take to reduce lead exposure through public notices and public-education programs.

The LCR established an action level of 0.015 mg/L for lead and 1.3 mg/L for copper. An action level is not the same as a violation. If levels of lead or copper are detected above the action level, however, the utility may have to take certain actions:

* water quality parameter monitoring: adopt more stringent testing, addressing both the distribution system and pH levels;

* corrosion control treatment: develop methods for making the water less corrosive and therefore less likely to leach lead or copper from plumbing;

* source water monitoring and treatment: sample source water to rule out supply as a source;

* lead service line replacement: replace at least 7 percent of lead lines each year and more if the state requires; and

* public education--inform customers when action levels are exceeded and let them know about ways to reduce lead levels in homes.

If a water system, after installing and optimizing corrosion control treatment, still doesn't meet the standard of the lead action level, it must begin replacing lead service lines. Systems serving more than 50,000 people were required to conduct studies of corrosion control and to install state-approved optimal-corrosion-control treatment by January 1, 1997. Small and medium-sized systems are required to optimize corrosion control if samples taken at consumers' taps show lead or copper exceeding the action level.

In January 2000, U.S. EPA adopted the Lead and Copper Rule Minor Revisions (LCRMR), which streamline requirements, promote consistent national implementation, and, in many cases, reduce burdens for water systems. The LCRMR do not change the original action level.

What Does the LCRMR Do?

The original LCR specified the number of sample sites on the basis of system size. Systems are required to take samples every six months unless they have readings lower than action levels over two consecutive monitoring periods, in which case they qualify for reduced monitoring.

The revisions make clearer what is expected from water systems:

* They are required to operate and maintain optimum corrosion control parameters.

* Even after the systems are deemed to have optimized corrosion control, they are required to monitor water quality parameters.

* The revisions specify the number and locations of tap water-sampling sites.

* They spell out what will trigger resampling for composite source water samples.

The effective date of LCR revisions is April 11, 2000. Systems should check with their state primacy agencies, however, because not all provisions may apply in their state.

The U.S. EPA Review: What Did It Find, and What's in Store?

A 2004-2005 U.S. EPA study found that the LCR had been effective in more than 96 percent of systems serving 3,300 or more people. U.S. EPA decided to launch a Drinking Water Lead Reduction Plan to "strengthen, update, and clarify existing requirements for water utilities and states to test for and reduce lead in drinking water."

By early 2006, U.S. EPA plans to propose regulatory changes to the LCR in the following areas:

* monitoring: to ensure that water samples reflect the effectiveness of lead controls, to clarify the timing of sample collection, and to tighten criteria for reducing the frequency of monitoring;

* treatment processes: to require that utilities notify states prior to changes in treatment so that the states can provide direction or require additional monitoring; and, through revision of existing guidance, to help utilities maintain corrosion control while making treatment changes;

* customer awareness: to require that water utilities notify occupants of the results of any testing that occurs within a home or facility, and to allow states and utilities to provide customers with utility-specific advice about tap flushing to reduce lead levels;

* lead service line management: to ensure that service lines that have tested below the action level are re-evaluated after any major changes to treatment that could affect corrosion control; and

* lead in schools: to update and expand 1994 guidance on testing for lead in school drinking water, and to emphasize partnerships with other federal agencies, utilities, and schools to protect children from lead in drinking water.

(Adapted, with permission, from On Tap, a publication of the National Environmental Services Center, Summer 2005, Volume 5, Issue 2. For a complete copy of the original article, visit www.nesc.wvu.edu/ndwc/ndwc_ontap.htm.)