Changes are being made to the drinking water Lead and Copper Rule (LCR). In accordance with the LCR, the Action Level for lead is 0.015 parts per million (ppm) and the Action Level for copper is 1.3 ppm. While the Action Levels for lead and copper will remain the same, the revised rule introduces a new Trigger Level for lead of 0.010 ppm (equivalent to 10 parts per billion (ppb)). Should your system reach the Trigger Level there are two possibilities:
· If your system already treats for corrosion, your system will be required to reoptimize the treatment.
· If your system does not treat for corrosion, your system will be required to conduct a corrosion control study so that the system is prepared to respond quickly when necessary.
The lead Trigger Level essentially provides an early indicator of corrosion control issues before reaching the lead Action Level. Similar to the Action Level, the Trigger Level will be based on the 90th percentile level of your system’s samples.
In addition to the corrosion control treatment evaluations, exceedance of the Trigger Level will move your system to annual sampling at the rule standard number of sites. To maintain a waiver for reduced sampling conducted triennially at a reduced number of sites, the 90% percentile must remain below the Lead and Copper Action Levels and the Lead Trigger Level.
The LCR revisions include changes to the requirements for when corrosion treatment will be required for systems with populations less than 50,000. The original LCR included a provision to discontinue efforts to implement corrosion control treatment if the system no longer exceeded both Action Levels for two consecutive 6-month monitoring periods. The revised LCR state that systems which have a lead sample round with 90th percentile in exceedance of the Action Level, the system must complete corrosion control treatment regardless of their subsequent 90th percentile levels.
The proposed LCR revisions include additional provisions. Be on the lookout for more information. EPA anticipates issuing the final rule in 2020. Refer to EPA’s website for more information: https://www.epa.gov/ground-water-and-drinking-water/proposed-revisions-lead-and-copper-rule
Please contact ResilientCE with your LCR questions at admin@resilientce.com.
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