A water quality crisis rose to the nation’s attention when health issues began to plague the residents of Flint, Michigan in 2014.

In response to contaminated water discovered in the Flint community, the Environmental Protection Agency (EPA) has sought to improve the national Lead and Copper Rule (LCR). There are important new requirements and the date for compliance is quickly approaching. Many of the requirements will require new testing and reporting. With a desire to fully comply, IPA Laboratories has been asked about water testing for lead and copper that will be required. I’ve outlined below some key points to understand.

The LCR was first established in 1991 as an attempt to control the levels of lead and copper in drinking water. According to the EPA, lead and copper enter drinking water when plumbing materials corrode, especially where water has high acidity or low mineral content.

An infographic from the EPA detailing the sources of lead in drinking water.

Source: EPA.gov/safewater

The most common sources of lead are from lead pipes, faucets, and fixtures. These are more likely to be found in homes built prior to 1986. Exposure to lead and copper may cause health problems ranging from stomach distress to brain damage.

An addendum to the LCR was issued in 2021 called the Lead and Copper Rule Revision (LCRR) and included new requirements to further protect people from exposure to lead and water contamination. Additionally, in 2023 the EPA published the Lead and Copper Rule Improvements (LCRI), including these new requirements for water utilities:

Develop a lead service line inventory of all water service lines and make the inventory available to the public.

  • Submit an initial service line inventory to their state for all Community Water Systems (CWS) and non-transient non-community water systems (NTNCWS) by October 16, 2024.
  • Develop a lead service line inventory of all water service lines and make the inventory available to the public.
  • Submit an initial service line inventory to their state for all Community Water Systems (CWS) and non-transient non-community water systems (NTNCWS) by October 16, 2024.
  • Include all service lines connected to the public water distribution system in the inventory, regardless of ownership status.
  • Characterize each service line as lead, galvanized requiring replacement (GRR), lead status unknown, or non-lead using approved sources.
  • Update inventories annually based on tap sampling frequency.

Develop a lead service line replacement plan.

  • Accomplish full replacement of all lead and galvanized service lines within 10 years, with limited exceptions.

Sample schools and childcare facilities for lead and copper.

  • Collect samples from 20% of schools and 20% of childcare facilities each year achieving 100% within five years, rotating 20% each year.
  • Provide results to the schools (cannot be used as the school’s compliance sampling).

A lab technician filling a plastic testing bottle with water from aa drinking fountain.

Source: EPA.gov

Improve Tap Sampling.

  • Continue “First Liter Sampling” to sample the initial first liter from the line, after the water has sat stagnant for minimum of six hours
  • Add “Fifth Liter Sampling” to sample water that is collected after the initial liter sample and has sat stagnant for minimum of six hours.
  • Use the higher of the two values of First Liter or Fifth Liter sampling for compliance reporting.
  • Use a wide-mouth bottle for sampling.
  • Collect tap samples at locations served by replaced lines within three to six months after replacement.

Strengthen treatment to comply with the new 10 ug/L (ppb) trigger level.

  • Comply with new lead trigger level at 10 ug/L (ppb).
  • Inform the public whenever the new threshold of 10 ug/L (ppb) is exceeded, act to reduce lead exposure, and work to replace all lead pipes. For example, corrosion control treatment is implemented while working to replace pipes.

Communicate with the public about the LCRR’s requirements and the steps taken to meet the requirements.

  • Provide public access to the lead service line inventory and include locations for lead and galvanized requiring replacement (GRR) service lines. (Water systems serving greater than 50,000 persons must make the publicly accessible inventory available online.)
  • Notify the public within three days when lead levels are greater than 15 ppb. For levels less than 15 ppb, notifications should be sent within 30 days. System-wide exceedances require notification within 24 hours.
  • Notify customers annually if they are served by lead, GRR, or an unknown service line.
  • Provide revised lead health effects language in public education materials.
  • Provide filters certified to reduce lead within 24 hours for six months after replacement.

With the updates, revisions, and improvements to the original Lead and Copper Rule, the EPA believes it can better protect communities and children from the risks of lead exposure. The EPA is currently reviewing comments on the LCRI addendum with plans to finalize it prior to the compliance date. The compliance date for both the LCRR and LCRI is October 16, 2024. Please reach out to me at mhyde@ipalaboratories.com with any questions you have about lead and copper water testing. Our team is ready to help!