EPA Lead and Copper Rule: Key Revisions (LCRR and LCRI) You Need to Know

Understanding the EPA Lead and Copper Rule (LCR)

• Lead: An action level of 15 parts per billion (ppb).
• Copper: An action level of 1.3 parts per million (ppm).

It’s crucial to understand that exceeding these action levels does not constitute a violation of the rule. Instead, it triggers mandatory additional actions, including increased monitoring, corrosion control measures, and public education to reduce risks and inform affected consumers about protective measures.

Health Risks of Lead and Copper in Drinking Water

Lead exposure is particularly dangerous due to its severe and lasting effects on health. Young children and pregnant women are especially vulnerable to lead in drinking water. Health risks associated with lead exposure include:

• Brain and neurological damage
• Developmental delays
• Kidney damage
• Blood disorders

Copper exposure, though less widely recognized, also carries significant health risks. Elevated copper levels can lead to:

• Gastrointestinal distress, including stomach and intestinal issues
• Long-term liver and kidney damage
• Complications for individuals with Wilson’s disease, a genetic disorder affecting copper metabolism

Key Changes in the Lead and Copper Rule Revisions (LCRR 2021) and Lead and Copper Rule Improvements (LCRI 2024)

New Lead Action Level and Trigger Level

• Original lead action level under LCR: 15 ppb.
• New trigger level introduced by LCRR: 10 ppb lead.
• New action level under LCRI: 10 ppb lead.

Mandatory Lead Service Line Replacement (LSLR)

• Historically (original LCR), mandatory replacement was required after continued exceedances despite corrosion control measures.
• Under the LCRI, all lead and galvanized requiring replacement (GRR) service lines must be replaced within 10 years, irrespective of testing results, at a minimum annual rate of 10%.
• The water system’s “control” over service lines refers to having legal or physical access to conduct replacements.

Revised Sampling Protocols (Fifth Liter Sampling)

Fifth-liter sampling, introduced under the LCRR, significantly impacts lead compliance for water systems, especially those with lead service lines (LSLs). The fifth-liter sample better captures water that has stagnated in LSLs, resulting in a more accurate measure of potential lead exposure. This new requirement is expected to:

• Lead to higher reported lead concentrations, potentially causing more systems to exceed lead action or trigger levels.
• Trigger increased monitoring frequency, corrosion control re-optimization, and accelerated lead service line replacements.
• Necessitate adherence to revised sampling protocols, rendering previous first-liter sampling data inadequate for compliance demonstration.
• Require systems with LSLs to exclusively sample homes with LSLs using fifth liter sampling, focusing resources and attention on higher-risk locations.

Enhanced Public Notification Requirements

• Tier 1 public notification required within 24 hours upon exceeding the action level, effective October 16, 2024 (LCRR).
• Expanded public education requirements, including clearer communication, multilingual notices, renter-specific outreach, and encouragement of participation in lead service line replacements.

Required Lead Testing in Schools and Childcare Facilities

• Mandatory lead testing in elementary schools and childcare facilities, targeted for completion within five years.
• Required public education to ensure understanding and preparedness regarding lead risks.

Distribution of Point-of-Use Filters

• Under LCRI, water systems exceeding the lead action level three or more times in a five-year period must provide certified lead-removal filters to customers.

Comprehensive Service Line Inventory Requirements Under LCRR/LCRI

Under the LCRR and LCRI, water systems must maintain a detailed and publicly accessible inventory of all service lines, including both public and private sides. The inventory must document:

• Known lead service lines.
• “Galvanized requiring replacement” (GRR) lines, previously connected to lead pipes.
• Lines with unknown material, classified as “lead status unknown.”

Customers with identified lead, GRR, or unknown service lines must receive annual notifications clearly outlining potential health risks. The LCRI further mandates an updated baseline inventory, covering all service lines and connectors regardless of ownership, guiding targeted replacement efforts and sampling strategies. Local governments are tasked with identifying and replacing unknown or unverified lines, especially galvanized lines downstream of lead components, to ensure community safety and compliance.

Actions Required Upon Exceeding Lead Action Levels

When lead action levels are exceeded, several mandatory actions must be undertaken by water systems:

• Public notification: Tier 1 notification to consumers within 24 hours.
• Corrosion control re-optimization treatment: Enhanced treatments to minimize lead corrosion.
• Enhanced public education: Informing consumers clearly about lead health effects, prevention, and steps to minimize exposure.
• Mandatory lead service line replacement: Systems must replace lead service lines at defined annual rates. In most cases, this involves replacing 10% of lead service lines per year, with a goal of fully replacing all lead service lines by 2037.
• Certified lead-removal filters: Required availability of filters for customers after multiple exceedances.

The updates from LCR to LCRR and LCRI reflect a proactive, enhanced approach to public transparency, consumer education, and health protection, emphasizing swift responses and ongoing prevention measures.

Preparing for Compliance: Roles for Cities and Property Owners

Cities and water systems play a primary role in compliance:

• Develop comprehensive inventories of all service lines, updating annually and making them publicly accessible.
• Prepare detailed lead service line replacement plans, aiming to replace 10% annually.
• Implement revised sampling protocols, prioritizing fifth-liter samples for homes with LSLs.
• Conduct regular lead testing in schools and childcare facilities.
• Optimize corrosion control treatments based on sampling results.
• Prepare rapid public notifications and educational outreach, especially after action level exceedances.
• Ensure the availability of certified lead-removal filters after repeated exceedances.
• Secure funding to support these initiatives.

Property owners should:

• Cooperate with water systems to verify service line materials.
• Pay close attention to notifications about potential lead exposure.
• Participate in service line replacement programs.
• Utilize the provided filters as instructed.
• Stay aware of internal plumbing conditions and advocate for comprehensive local water safety policies.

By engaging collaboratively, both cities and property owners can achieve compliance and ensure safer drinking water for communities.

Looking Forward: Safer Water for All

Recent updates to the EPA’s Lead and Copper Rule significantly strengthen drinking water safety and transparency, marking a substantial advancement in public health protection. Proactive measures such as comprehensive service line inventories, mandatory lead service line replacements, and improved fifth-liter sampling protocols serve as transformative steps in reducing lead exposure.

To achieve compliance, both cities and property owners must actively prepare and engage with these new requirements. Solutions like Juno Maps provide valuable assistance to businesses and property owners, offering streamlined, intuitive geospatial tools to help efficiently manage lead service line inventories and remain compliant with these stringent regulations. By leveraging such innovative tools and collaborative efforts, communities can ensure safer drinking water now and for future generations.