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Lead & Copper Rule Resources for Water System Operators

As the operator of a public water system, remaining compliant with all the rules and regulations governing drinking water quality can be quite the challenge. The challenge becomes even greater as you struggle with simultaneous compliance with the entire gamut of rules and regulations, with new requirements, or with changes to existing rules. The Lead & Copper Rule is, admittedly, difficult to navigate – and recent updates have created new responsibilities.

Operators are responsible for the quality of the drinking water they deliver to the customers’ tap. Lead and copper samples must be a first draw tap sample and are collected in distribution at the customers’ homes, not at the water system’s source or just subsequent to treatment. The Lead & Copper Rule requires the water system to select homes (buildings or taps) from high risk groups first. High risk structures include buildings with lead service lines, lead solder, or structures built between 1983 and 1986. The list of sampling sites must be submitted to the Vermont Water Supply Division and a lead and copper sampling plan must be approved. All public water systems classified as either Community Water Systems (CWSs) or Non Transient, Non Community (NTNC) Water Systems are subject to the requirements of the Lead & Copper Rule.

These pages were created to provide you with the resources needed to better understand your responsibilities under the Lead & Copper Rule; and to help you successfully fulfill them.

The Lead & Copper Rule
The purpose of the Lead and Copper Rule (LCR) is to protect public health by minimizing lead and copper levels in drinking water, primarily by reducing corrosivity. Lead and copper enter drinking water mainly from corrosion of lead- and copper-containing plumbing and fixtures. The LCR established action levels of 0.015 milligrams per liter (mg/L) or 15 parts per billion (ppb) for lead and 1.3 mg/L (1300 ppb) for copper based on the 90th percentile level of tap water samples. This means no more than 10 percent of samples can be greater than either action level. If lead or copper levels are found above the action levels, it does not signal a violation but can trigger other requirements that include water quality parameter (WQP) monitoring, corrosion control treatment (CCT) recommendation/installation, source water monitoring/treatment, public education, and lead service line replacement. 

Lead & Copper Rule Basics
 A PowerPoint presentation covering Lead and Copper Rule Basics as well as a Rule Update is available by downloading the following:

Lead & Copper Sampling Plan Guidance and Form

How Do I Collect Lead & Copper Tap Water Samples (including directions for homeowners)

Calculating Lead & Copper 90th Percentile Values

The Corrosion Control Treatment Requirements

Water Quality Parameter Sampling

Making a Corrosion Control Treatment (CCT) Recommendation

 

Lead & Copper Rule: Returning To Compliance (RTC)

Best Management Practices for Reducing Lead and Copper in the Distribution System

Vermont’s Lead-Free Law
Vermont Statue, Title 9, Chapter 63 Section; 2470h(2)
Lead-Free Law Now in Effect [includes a listing of fixtures subject to and not subject to the statutory lead limit]

Emerging Issues

Short Term Revisions to the Lead & Copper Rule
The Lead & Copper Rule was originally promulgated by the U.S. Environmental Protection Agency (EPA) on June 7, 1991. The Rule was modified with minor revisions on January 12, 2000. More recently, Short Term Revisions and Clarifications were published October 10, 2007.

The LCR and Revisions apply to all community and non-transient non-community public water systems. The revisions do not amend the portion of the regulations related to copper nor change the action levels for lead or for copper. Key provisions of the rule revision include:

  • Minimum number of samples required. The revisions give the State the discretion to allow systems that have fewer than five water taps to only collect one lead/copper sample from each tap that can be used for human consumption (although the highest lead and copper values are then the 90th percentile values).
  • Definitions for “compliance period” and “monitoring period”. Clarifications throughout the rule explain when compliance and monitoring periods begin and end. These clarifications help define the timing of actions following a lead or copper action level exceedance, the timing of monitoring activities related to reduced monitoring schedules, as well as the new reporting requirements.
  • Reduced monitoring requirements. EPA is no longer allowing owners of water systems that exceed the lead action level of 0.015 mg/L to initiate or remain on a reduced lead and copper monitoring schedule based solely on the results of their water quality parameters (WQPs). Systems will now also be required to remain below the lead action level in addition to optimizing their water quality parameters. (WQPs are a set of parameters or limits such as pH, alkalinity, calcium, and temperature chosen as indicators of whether a particular corrosion control treatment is being properly operated and maintained.)
  • Consumer Notice of Lead Tap Monitoring Results. EPA added new consumer notice requirements that require all public drinking water system owners to provide consumers who occupy homes or buildings, which are part of the system’s monitoring program, with the monitoring results when their drinking water is tested for lead (including those who do not receive water bills). This requirement includes all sample results, even those results that do not exceed the action level of 0.015 mg/L. The revisions specify the timing, content, and delivery methods for this particular consumer notice.
  • Advanced notification and approval of long-term treatment changes. The revisions require water system owners to receive approval from the State before adding a new source or making any long-term treatment change.
  • Public education requirements. EPA changed the public education requirements in the revised rule. System owners are still required to deliver public education materials after a lead action level exceedance. However, EPA made significant modifications to the content of the written public education materials and added a new set of delivery requirements.
  • Reevaluation of previously “tested out” lead service lines. The revisions require water system owners to reconsider any water distribution lines previously “tested out” (i.e., determined to not require replacement) when resuming lead service line replacement programs.
  • Lead language in CCR. The revisions require water system owners to incorporate mandatory language about lead in drinking water in the Consumer Confidence Report. Such language includes information about possible health effects in vulnerable populations and what consumers can do to reduce exposure to lead in drinking water.

Resources to Help You Comply with the Short Term Revisions

Consumer Notice of Lead Tap Results (Certification Form)

How do these revisions change the public education requirements?
EPA requires water systems to deliver public education materials after a lead action level exceedance. The new rule changes the content of the message to be provided to consumers, changes how the materials are delivered to consumers, and the timeframe in which materials must be delivered. Also, there are changes to the delivery requirements which include additional organizations that systems must partner with to disseminate the message to at-risk populations as well as changes in the ways information is disseminated to ensure water systems reach consumers when there is an action level exceedance. The new rule also requires educational statements about lead in drinking water to be included in all Consumer Confidence Reports. 

Lead Public Education Resources

Lead & Copper in Drinking Water: Resources for Schools and Daycare Centers

 

 

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