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Water: Lead & Copper Rule

National Review of LCR Implementation and Drinking Water Lead Reduction Plan

Beginning in 2004, EPA conducted a wide-ranging review of implementation of the Lead and Copper Rule (LCR) to determine if there is a national problem related to elevated lead levels. Our review placed a focus on determining if the existing rule is being effectively implemented by states and local communities and on identifying where additional guidance or changes to the regulation are needed to improve implementation. During 2004, Congress held a number of oversight hearings to further investigate implementation of the LCR in the District of Columbia and the nation.

Drinking Water Lead Reduction Plan

In March 2005, EPA announced its plan for actions the Agency would undertake in response to its review of the Lead and Copper Rule. Our year-long evaluation did not reveal a national problem comparable to the situation observed in the District of Columbia in 2004. However, based on the information derived from our review we identified opportunities to improve and clarify specific areas of the rule and our guidance materials. In an effort to improve implementation, we initiated several actions in 2005. We will continue to address a number of other actions over a longer time frame because they require additional information collection and/or research. EPA will continue to evaluate implementation and update the plan as needed to reflect new information.

DC Review

EPA carried out an extensive study to evaluate factors that contributed to elevated levels of lead in drinking water for many residents served by the DC Water and Sewer Authority in the period between 2000 and 2004. The study found that a combination of factors – not a single source or event – contributed to the problematic release of lead in water at D.C. consumer taps.

Elevated Lead in D.C. Drinking Water – A Study of Potential Causative Events, Final Summary Report

National Review

During 2004 EPA undertook a number of activities to help the Agency identify needed actions. EPA:

  • collected and analyzed lead concentration data and other information required by the regulations;
  • carried out a review of implementation in states;
  • held four expert workshops to further discuss elements of the regulations, and;
  • worked to better understand local and state efforts to monitor for lead in school drinking water, including a national meeting to discuss challenges and needs.
Review of Data to Evaluate Effectiveness of Rule

As part of its review, EPA has reviewed data from its Safe Drinking Water Information System to determine the extent of elevated lead levels at water systems throughout the country. The Agency’s review showed that 96% of the utilities that serve more than 3,300 people in the country were below the action level. The Agency also reviewed monitoring results for a number of large systems which conducted monitoring in 1992/93 just after the rule was issued and compared the data to the results from their most recent monitoring. Only 15 of 166 systems were still above the action level.

Review of Implementation by States and Utilities

In 2004, EPA carried out a review of implementation of requirements of states and utilities. The review identified some areas in which there was confusion about the existing regulations. EPA partially addressed some of these issues by releasing guidance in November 2004 on requirements related to monitoring and management of samples. Several additional issues are addressed through the regulatory revisions that will be proposed as part of the plan and others will be addressed through renewed oversight of state programs.

Expert Workshops

In 2004 and 2005, EPA convened five expert workshops. The workshops were focused on monitoring, simultaneous compliance, public education/risk communication, lead service line replacement, and lead content in plumbing fittings and fixtures. Information derived from the workshops was used to help the Agency identify where changes could be needed to regulations and guidance.

  • Simultaneous Compliance - May 11-12, St. Louis, Missouri
    Participants discussed the challenges public water systems face in complying with corrosion control optimization requirements of the lead and copper rule at the same time they must comply with other treatment techniques and maximum contaminant levels (MCLs). Experts identified a number of topics for which further Agency guidance would aid water systems in evaluating treatment changes, including: disinfection changes, changes to coagulation processes, and corrosion inhibitors treatments. The experts also identified concerns with distribution system maintenance and the impacts of household plumbing on a system’s ability to comply with the lead and copper rule.
  • Sampling Protocols - May 12-13, St. Louis, Missouri
    Participants discussed the challenges of the sampling requirements of the lead and copper rule as well as the strategies they have used to ensure compliance. Several participants suggested EPA review Lead and Copper Rule sampling provisions, including: sampling frequency and triggers,sampling site selection/location, sampling protocols, and sampling of water quality parameters. Experts also identified a number of topics for which there are information gaps and issues they believe warrant future workshops.
  • Public Education - September 14-15, Philadelphia, PA
    Participants discussed the public education requirements under the lead and copper rule, drinking water risk communication, and effective
    communication with the public. Participants suggested ways to improve risk communication to the public through establishing partnerships with health departments and other groups, refining the message content, improving delivery of the message, and spending more time planning and evaluating the effectiveness of the risk communication.
  • Lead Service Line Replacement - October 26 - 27, 2004, Atlanta, GA
    Participants discussed the lead service line replacement requirements of the Lead and Copper Rule including experiences with full and partial replacement, post-replacement monitoring and lead service line inventory management. Participants suggested ways to improve lead service line replacement programs including more effective replacement techniques, steps to motivate customers for full replacement, and improved post-replacement monitoring and flushing.
  • Lead in Plumbing Fittings and Fixtures - July 26 - 27 Washington, DC
    Participants discussed the potential issues associated with lead in plumbing fittings and fixtures, including their potential to leach lead into water, existing standards and test protocols, utility challenges, and manufacturer perspectives . Participants suggested ways to improve NSF testing procedures; identified a number of actions to improve implementation of standards at national, state, local and consumer levels; recommended potential modifications to the Lead and Copper Rule; and requested updated health effects information related to lead in drinking water.

National Drinking Water Advisory Council

In 2005, EPA charged the National Drinking Water Advisory Council with reviewing the public education requirements associated with Lead and Copper Rule.  The Council formed a workgroup to consider the issue.  In 2006, the Council provided EPA with preliminary recommendations on proposed changes to regulatory requirements for public education.  In 2006, the Council will also provide the Agency with recommendations on how to revise the existing public education guidance.

Lead in School Drinking Water

Children are particularly vulnerable to lead exposure. EPA requested information from state environmental and health agencies on existing programs that focus on monitoring for lead in drinking water (for PWS and non-PWSs) and developed a summary report of the findings. Based on the findings, EPA saw a need to work with States to help schools and child care facilities that are a public water system understand the requirements of the existing regulations. EPA also hosted a meeting in December 2004 to discuss school and child care facilities drinking water issues. Participants included representatives from the Department of Education, Centers for Disease Control and Prevention, state associations representing schools and child care facilities, state public health program staff, water utilities, and environmental and educational advocate organizations. In addition to updating the existing 1994 guidance, as described in the plan, we entered into a memorandum of understanding with other federal agencies and associations representing state drinking water programs and water utilities to promote voluntary activities to reduce children’s exposure to lead in drinking water.

Congressional Testimony


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