Improving Water Quality Through Lead and Copper Rule Enhancements: Science and Technology for Compliance
The Lead and Copper Rule (LCR), first published in the Federal Register in 1991, was established to safeguard public health by controlling the amount of lead and copper in drinking water. Given the harmful effects these metals can have on human health—particularly among vulnerable populations such as children and pregnant women—the LCR was created to minimize exposure that results from the corrosion of plumbing materials containing lead and copper. Replacing the numerical standards that previously had been measured at the entry point to the distribution, the LCR set standards for acceptable lead and copper levels and strategies to reduce water corrosivity to prevent lead poisoning, which can lead to severe developmental and health issues, and mitigate adverse health effects associated with copper exposure. Through ongoing revisions and improvements, the LCR continues to enhance its protective measures, ensuring cleaner and safer drinking water for communities across the United States.
Introduction of the Lead and Copper Rule Revisions
Between 1991 and 2020, there were several minor revisions to the LCR until major changes were incorporated via the Lead and Copper Rule Revisions (LCRR), which was published to the Federal Register in 2021. In general, the LCRR focused on identification and replacement of lead service lines and galvanized service lines downstream of lead lines (galvanized requiring replacement [GRR]), notification requirements, and updated sampling requirements for compliance. Almost concurrently with the publishing of the LCRR, the US EPA announced there would be further evaluation of requirements and that the agency would be considering additional actions related to lead and copper exposure from drinking water.
As a result of these further considerations, the US EPA published the Lead and Copper Rule Improvement (LCRI) on October 30, 2024, with an effective date of December 29, 2024. The LCRI presents an accelerated schedule to identify and replace lead and GRR service lines, requires more rigorous sampling and testing of drinking water, lowers the threshold of these contaminants, and includes additional requirements for treatment and community outreach for water systems with action level exceedances.
The 2021 LCRR required initial service line inventories to be submitted by October 16, 2024. The LCRI requires a more robust baseline inventory to be conducted and submitted that includes total numbers of lead, GRR, unknown, and non-lead service lines, lead connectors, and connectors of unknown material. The LCRI allows for an additional 3 years to complete baseline inventories but also presents a more accelerated schedule of 10 years to replace the identified components. It also requires making this information publicly available in some cases.
Updated Sampling Protocols
The LCRI presents changes to sample collection protocol based on identified best practices currently in use by states such as Michigan. For sites with lead service lines, water systems are required to collect the first liter and fifth liter of water during compliance sampling. The data from the sample with the higher concentration must be used for determining compliance. In contrast, the LCRR required first-draw (equivalent to first liter) sample collection only. Properly collected samples are then sent to accredited laboratories for analysis. The final LCRI reduces the lead action level from 15 µg/L to 10 µg/L while the copper action level remains unchanged at 1.3 µg/L under the LCRI.
Water systems with exceedances of these new action levels are required to continue adjusting treatment to reach compliance. The LCRI also mandates additional public outreach and distribution of filters that are certified to reduce lead concentrations to all serviced customers with an impacted water supply.
The Role of Science in Compliance
Compliance with the LCRI will require a unique combination of science and technology. The updated sampling protocols and analytical requirements highlight the need for field sampling procedures that generate representative samples and the selection of the most appropriate laboratory to perform the sample analysis. The use of innovative technologies to assist with material inventory, public outreach, and treatment options are necessary to achieve regulatory compliance in the most efficient way possible.
The LCRI impacts all community water systems and non-transient, non-community water systems across the United States and will benefit all who are serviced by these providers. Providers subject to LCRI requirements can benefit greatly from sampling and analysis quality assurance programs and spatial software and visualization tools. Environmental Standards, along with other divisions of our parent company Montrose Environmental, have the scientific and technological expertise to assist in reaching your compliance goals.
